Thursday, February 9, 2012

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ANALYSIS: SEC Enforcement Manual Revisions Feature Measures to Encourage Cooperation

On January 13, 2010, the Securities and Exchange Commission unwrapped version two of its Enforcement Manual, first introduced in 2008. Revisions to the Manual implement various initiatives of the Enforcement Division’s new leadership, but the change drawing the most attention is the addition of a robust cooperation policy. This article analyzes the new cooperation policy and other important changes in the Manual that will most impact SEC defense counsel and their clients…

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