June 4, 2004

Enforcement’s New “Wildcatting” Philosophy Recently,

Recently, the SEC’s Enforcement Division has signaled a change in philosophy – from a reactive approach (i.e. investigations of individuals or companies were initiated after evidence of a possible violation surfaced) to “seeing around the corner.”

In this interview with Bill Baker on the SEC Staff “Wildcatting” for Fraud, Bill – who recently left as an Associate Director in Enforcement to join Latham & Watkins – explains how Director Stephen Cutler has a desire to foster a cultural change within the enforcement program to encourage more risk taking when pursuing investigations where, at the outset, it is not clear that a securities violation has occurred. This also is known as “wildcatting.”

Hats Off to Cecilia Blye!

Yesterday, Cecilia Blye was promoted to head Corp Fin’s new Office of Global Security Risk. As Cecilia has been a staple in the Office of Chief Counsel for some time, many of you might have dealt with her over the years. She is an absolute sweetheart and I bet many staffers will be applying to serve under her experienced and steady hand.