Debevoise & Plimpton LLP white collar partner Kara Brockmeyer recently commented to The Wall Street Journal about the implications of the SEC’s rollback of policy that gave public companies confidence as to whether they would maintain access to key regulatory exemptions after settling securities law violations.

In the Journal’s February 16, 2021, article, SEC Signals a More Aggressive Stance Toward Wall Street, Ms. Brockmeyer noted, “[t]he pieces are in place for an aggressive era of enforcement,” and that the change could complicate settlement negotiations. “It’s kind of like pleading guilty when you don’t know what the judge is going to sentence you to,” she added.

A Debevoise Update on this topic authored by Ms. Brockmeyer along with white collar partners Andrew Ceresney, Arian June and Robert Kaplan addresses this topic in more detail. In the Update, the partners provide key takeaways from the SEC’s recent announcements on the rollback, which signal a more aggressive approach to enforcement and market regulation in the new Administration.