How the SEC’s New “User-Friendly” Manual Provides Uniformity, Law360
February 26, 2026Law360 quoted partner Carolyn Welshhans in an article about the US Securities and Exchange Commission’s (SEC’s) recent updates to its enforcement manual, the first since 2017.
The changes were made to standardize the agency’s practices and increase transparency, but Carolyn warned it was not a given that prospective defendants would get full access to an investigative file under the updated procedures.
“I think Wells recipients and their counsel should be careful not to overread these changes. There’s an expectation of greater transparency and access here, but I think that there are going to be instances where the SEC believes it does not need to follow regular procedures. And so I don’t think that people should expect it in every single instance,” Carolyn said.