TheCorporateCounsel.net

January 10, 2013

The Exodus is Complete: SEC’s Enforcement Director Khuzami to Leave

So the rumor was true. Yesterday, the SEC announced that Enforcement Director Rob Khuzami would be leaving the agency after a 4 year tenure. No word as to his next employer – but I imagine it will be lucrative as Enforcement Directors typically earn the most once they depart the agency (which is why Bill McLucas’ 8-year stint was always a surprise). Rumored replacements are named in this DealBook piece. Rob’s departure means that 3 Division Directors and the General Counsel have all announced departures since Chair Mary Schapiro announced her exit. Wow…

Exodus, movement of Jah people

Will the SEC Propose Rules on Corporate Political Spending by April?

Ning Chiu of Davis Polk asks the question that I received from so many of you after Prof. Lucian Bebchuk blogged yesterday that the SEC would propose rules in the political spending area by this April (you may recall that Lucian’s co-sponsored rulemaking petition in this area has drawn over 320,000 comments!). Lucian’s prediction was based on some language in the Office of Management and Budget’s Unified Agenda. As Ning blogged, the OMB Unified Agenda includes a list of potential SEC rulemakings with fairly extensive and ambitious timetables.

I think the key term here is “ambitious.” All kinds of whacky and aspirational stuff makes it into the Reg Flex agenda, which then winds up as part of the OMB Unified Agenda (in this blog, Keith Bishop explains what the OMB Unified Agenda is). So it’s hard to read the tea leaves on this one – although the massive turnover among the SEC’s senior staff and the 2-2 split among political parties in the Commission itself makes this bet one where you should seek long odds when it comes to an April timetable for an actual proposal. Then again, this topic is white hot right now…

More on “The Mentor Blog”

I continue to post new items daily on our blog – “The Mentor Blog” – for TheCorporateCounsel.net members. Members can sign up to get that blog pushed out to them via email whenever there is a new entry by simply inputting their email address on the left side of that blog. Here are some of the latest entries:

- Delaware Holds Insured’s Payment of Defense Costs Doesn’t Trigger Excess Insurer’s Obligations
- Should You Really Sit on Other Boards When You’re a Startup Founder?
- Delaware Court Addresses Caremark, Race to the Courthouse
- Survey: Boards on Auditor Rotation, Proxy Advisory Firms & More
- A Comprehensive Survey of ESG Studies

- Broc Romanek