Earlier this week at the Los Angeles County Bar Associations 56th Annual Securities Regulation Seminar, SEC Enforcement Director Meg Ryan delivered her first remarks since her appointment to the position back in August 2025. This speech gives us fresh insight into the SEC’s Enforcement Program and the potential areas of focus going forward.

In the speech, Judge Ryan indicated that her guiding principles as Director of the Division of Enforcement are “integrity, honor, fidelity to the law, and an unwavering commitment to the fair and judicious use of the formidable power and resources the federal government.” Acknowledging recent criticism of the Division, she noted:

Now, I am acutely aware of the criticisms of how the Division operated in the past, some of which I think are valid and warranted course correction. But I will not let the Division be weighed down by criticism that is misinformed, has been remedied, or only exists as historical artifact. Our mission – of protecting investors; maintaining fair, orderly, and efficient markets; and facilitating capital formation – is too important.

On the topic of process, Judge Ryan discussed the importance of the Wells submission process and confirmed the four-week window that proposed defendants or respondents have to make a submission explaining why the Commission should not authorize an enforcement action. She noted that a member of the enforcement senior leadership team will attend every Wells meeting, and provided assurance that all Wells submissions will be read and carefully considered. Judge Ryan warned that deliberate circumvention of the process, including “tactical tardiness and other games,” will not be tolerated.

With regard to the Division’s priorities, Judge Ryan noted reports that “enforcement work at the SEC has been tossed to the wayside are not only greatly exaggerated but flat out wrong.” She noted that:

A principal focus of our enforcement program is thus to protect investors from the myriad fraud schemes cooked up by bad actors, which Chairman Atkins refers to as the liars, cheats, and thieves. Identifying, rooting out, and remedying scams, particularly those that inflict devastating costs on everyday retail investors, is the cornerstone of what we do. Our work will continue to focus on uncovering and deterring fraud that wipes out American investors’ retirement savings, or fraud that undercuts their progress towards saving for a home, or their kids’ education. And we will make full use of the remedies available to return money to investors harmed by those frauds.

Likewise, we will continue to charge violations of the securities laws for misconduct that clearly undermines market integrity, including accounting fraud, insider trading, wash trading, and market manipulation schemes. This critical work ensures that appropriate market forces, not bad actors, determine the value of securities.

She also addressed compliance with other provisions of our federal securities laws, including a public company’s reporting requirements and obligations to maintain adequate books and records and devise and maintain systems of internal accounting controls, or a broker-dealer or investment adviser’s obligation to adhere to its fiduciary duties and financial responsibility rules. On this front, she noted:

Are violations of these provisions on par with fraud? No, not necessarily. In fact, I am confident that many violations of these provisions should not – and do not – result in enforcement cases by the Commission. But there is a middle ground: where fraud is absent, but compliance has failed in a way that poses risks to investors, risks to the integrity of the market, or yields a benefit to the participant. It is a place that may warrant enforcement action but may also present opportunity. Opportunity for both the Division and those who might be subject to an enforcement action to craft thoughtful resolutions in an appropriate case – resolutions that recognize wrongdoing while rectifying the violation or charting a firmer path toward compliance. Because – at the end of the day – our work in this space is about ensuring participants in our capital markets are providing investors with the necessary information and operating within the guardrails that make our capital markets the envy of the world. Where other divisions can identify, educate, and help people and entities remediate the problem or deficiency, fantastic.

In conclusion, Judge Ryan noted that we do not live in a perfect world, so the Division of Enforcement is necessary to address wrongdoing and violations of the securities laws.

– Dave Lynn