To Self-Disclose or Not Self-Disclose? Thoughts from SEC’s Enforcement Director
Highlights
At a recent securities regulation conference, Gurbir Grewal, director of the Securities Exchange Commission’s (SEC) Division of Enforcement, weighed in on the benefits of cooperating and self-reporting misconduct
The SEC has identified several influential factors it finds persuasive when assessing such cooperation
Engaging in early communication, being transparent in evidence gathering, and discussing areas of agreement or disagreement can prove critical to receiving consideration
Each company confronted with potential employee misconduct eventually faces the question: Should we report suspected misconduct to government authorities? That analysis can be particularly challenging for entities regulated by the Securities Exchange Commission (SEC). At a recent securities regulation conference in Palo Alto, California, Gurbir Grewal, director of the SEC’s Division of Enforcement, took the opportunity to give the Commission’s answer two key questions: What are the benefits of cooperating with the SEC? How does the SEC assess offered cooperation?
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