Enforcement Director Ryan Outlines SEC Division of Enforcement Priorities

On February 11, 2026, SEC Division of Enforcement Director Margaret Ryan delivered her first public speech since her appointment in September 2025. At the Los Angeles County Bar Association’s 56th Annual Securities Regulation Seminar, Ryan stated that “reports that enforcement work at the SEC has been tossed to the wayside are not only greatly exaggerated but flat out wrong.” She outlined her approach to the Wells process and reaffirmed the Division’s focus on core fraud and market integrity cases, emphasizing fairness, transparency, and timely resolution. Her remarks provide insight into how the Division intends to engage with parties under investigation. Key takeaways from the speech are summarized below.

• Wells Process. Ryan underscored the value of the Wells process in demonstrating the SEC staff’s commitment to a transparent and appropriate process. She confirmed that proposed defendants or respondents now have four weeks to make a Wells submission, extending the customary two-week deadline (which was often extended). As to the substance of Wells submissions, Ryan advised that defense counsel should focus on addressing key issues of fact or law. She stated that each submission will be read and carefully considered. Although she did not commit to attending all Wells meetings, Ryan stated that a “member of the enforcement senior leadership team” would do so.

• A Warning to Defense Counsel? In a pointed comment directed at defense counsel, or perhaps at the billable hour generally, Ryan stressed the need for reasonable and timely resolution, warning that “[d]eliberate circumvention of the process . . . including tactical tardiness and other games, will not be tolerated. Make no mistake, counsels’ incentives, financial or otherwise, to prolong an investigation (and then complain about how long the investigation took) will be met by steadfast commitment to reasonable and timely resolution.”
• Enforcement Priorities. Fraud remains a central focus for Ryan. She said the Division will continue to detect, eliminate, and redress misconduct that harms everyday retail investors. Enforcement will also target conduct that undermines market integrity, including accounting fraud, insider trading, wash trading, and market manipulation schemes.
• Non-fraud Violations. Ryan also addressed non-fraud violations of the securities laws, such as those concerning reporting requirements, books and records, internal controls, and fiduciary and financial responsibility rules. Ryan explained that such violations should not automatically result in enforcement actions and are, in some cases, better addressed through resolutions that acknowledge misconduct, remediate deficiencies, and strengthen compliance. Among the factors that would determine whether an enforcement action is appropriate are whether conduct “poses risks to investors, risks to the integrity of the market, or yields a benefit to the participant.”
• Rejecting “Chasing Numbers.” Director Ryan’s speech was also notable for what it did not include: details on the number of recent actions or the dollar amount of penalties. Director Ryan rejected “chasing numbers” in favor of focusing on the “quality and impact of the enforcement actions,” reflecting Chairman Paul Atkins’ shared view that the success of an enforcement program is not measured by statistics.