The Securities Enforcement Empirical Database (SEED) tracks and records information for SEC enforcement actions filed against public companies traded on major U.S. exchanges and their subsidiaries.
Created by the NYU Pollack Center for Law & Business in cooperation with Cornerstone Research, SEED facilitates the analysis and reporting of SEC enforcement actions through regular updates of new filings and settlement information for ongoing enforcement actions. The variables tracked include defendant names and types, violations, venues, and resolutions.
“Our goal is to shed light on the SEC’s securities law enforcement decisions. SEED is the first public database to provide easily searchable and verified data to researchers, counsel, and corporations, as well as regular reports on developments and trends.”
— Professor Stephen Choi, Director of the Pollack Center for Law & Business.
SEC Enforcement Activity: Public Companies and Subsidiaries (November 2021)
Key takeaways from the SEED research report for FY 2021 include:
- New actions against public companies and subsidiaries slowed to 53 actions, the lowest number since 2014. This is also 15% lower than FY 2020 and 32% lower than the average over the prior five fiscal years.
- Similar to FY 2020, Issuer Reporting and Disclosure allegations were the most common allegation type in FY 2021, accounting for more than half of all actions.
- Despite the decrease in the number of public company and subsidiary actions, SEC monetary settlements in these actions totaled $1.8 billion, in line with the FY 2012–FY 2020 average of $1.6 billion. The median monetary settlement in FY 2021 was $1 million, less than one-third of the average median from FY 2012 to FY 2020 and the lowest median since FY 2015.
- The SEC noted cooperation by 58% of public company and subsidiary defendants in actions settled in FY 2021, consistent with the FY 2012–FY 2020 average.
- The number of public company and subsidiary defendants with admissions of guilt decreased in each of the past two years, from five in FY 2019, to two in FY 2020, to zero in FY 2021.
This project is a collaboration between these organizations:
Pollack Center for Law & Business
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