Leading White Collar Lawyer Michael Leonard highlights 2024 SEED Findings. A report has been released by New York University, which collaborated with Cornerstone Research, based upon their investigation of the Security and Exchange Commission (“SEC”) trends with respect to enforcement. That Report is premised upon the SEC’s Empirical Database, also referred to as “SEED.”
As an initial matter, SEED categorizes public companies as those who were traded on a major United States exchange. As a result, certain companies are excluded from SEED, including but not limited to those who were traded “over-the-counter.”
Here is a summary of the Report:
1) the SEC filed 80 actions against public companies and their subsidiaries;
2) 38 of those actions were taken as part of five “sweeps:”
3) the most common allegation in such actions was “Issuer Reporting and Disclosure;”
4) perhaps not surprisingly, seventy-five percent (75%) of the defendants in those actions provided certain cooperation;
5) the monetary settlements for 2024 were approximately $1.5 billion;
6) the civil penalties for administrative proceedings were nearly $800 million in 2024; and
7) thirty-four (34) companies admitted guilt.
The Report can be found by way of the following link:
https://www.law.nyu.edu/sites/default/files/NYU-Cornerstone%20Report-FY%202024.pdf
It is titled: “SEC Enforcement Activity: Public Companies and Subsidiaries Fiscal Year 2024 Update.”
Michael Leonard
Leonard Trial Lawyers
January 22, 2025