How SEC Civil Penalties Became Arbitrary: The Framework

By David Slovick and Phil Lieberman ( January 21, 2026, 4:55 PM EST) -- In an Oct. 7 keynote address at the A.A. Sommer Jr. Lecture on Corporate, Securities and Financial Law, U.S. Securities and Exchange Commission Chairman Paul Atkins signaled his willingness to reconsider some of the verities of the SEC's enforcement process during his tenure at the agency, in particular, the conduct of the SEC's decades-old Wells process. He also offered his views on the importance of fairness in the SEC's enforcement process more generally:...

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