On February 11, 2026, at the Los Angeles County Bar Association’s Annual Securities Regulation Seminar, Margaret Ryan, the now former Director of the SEC’s Division of Enforcement, delivered remarks in which she discussed the Division’s enforcement process and outlined its enforcement priorities under her leadership. In her remarks, Director Ryan commented on recent changes to the enforcement process and highlighted the Division’s emphasis on the quality and impact of its enforcement actions, its principal focus on rooting out fraud, and general enforcement approach with respect to compliance with other provisions of the federal securities laws. Director Ryan resigned her position effective March 16, 2026, and Deputy Director Sam Waldon was named Acting Director.
Enforcement Process
Director Ryan noted the Division’s commitment to providing a fair and transparent process to individuals and entities involved in its enforcement investigations. In this regard, she highlighted recent updates to the Wells process, which is the process through which enforcement staff notifies respondents of charges under consideration. She noted that the Division will provide a longer, four-week window in which to respond to charges and that a member of the enforcement senior leadership team will attend every Wells meeting, during which respondents present their response to the SEC staff. Previously, the Division generally provided a two-week window in which to respond to potential charges.
Quality and Impact
Turning to enforcement priorities, Director Ryan underscored the importance of refocusing the Division’s resources on cases that further the SEC’s core mission. She dispelled the notion that enforcement work at the SEC had been “tossed to the wayside,” but noted that the Division will be focused on the “quality and impact” of enforcement actions rather than “chasing numbers.”
Focus on Fraud
Director Ryan emphasized that protecting investors against fraud will be a principal focus of the Division’s enforcement program, particularly fraudulent schemes that threaten the savings of retail investors as well as misconduct that undermines market integrity such as accounting fraud, insider trading, wash trading and market manipulation schemes. She noted that these efforts seek to ensure that appropriate market forces, rather than fraud, determine the value of securities.
General Compliance
Director Ryan also commented on the Division’s enforcement approach with respect to compliance with other provisions of the federal securities laws, including reporting requirements, obligations to maintain adequate books and records and maintain systems of internal accounting controls, and an investment adviser's obligation or a broker-dealer's to adhere to its fiduciary duties and the financial responsibility rules. She noted that, in circumstances where fraud is absent but compliance has failed in a way that poses risks to investors, risks market integrity or yields benefits to the participant, such circumstances may warrant an enforcement action or may present an opportunity for the Division and the participant to craft “thoughtful resolutions” that “recognize wrongdoing while rectifying the violation or charting a firmer path towards compliance.”
The transcript of Director Ryan’s remarks is available here.
