11/11 - These automatic bars (or carefully tailored waivers), however, have the potential to act as a powerful deterrent even to large institutions, something that should be considered every time a waiver is requested.

10/11 - Rohit Chopra is right that honest players are disadvantaged by repeat offenders, and even headline-grabbing penalties do not seriously deter the largest institutions.

9/11 - We should also continue to build on recent approaches to tailoring waivers to the unique risks that a firm presents, including by issuing time limited and/or conditional waivers and requiring C-Suite certifications, especially when addressing recidivists.

8/11 - More recently, recidivism & tone at the top have been taken more seriously. Going forward, we must be willing to impose the same sanctions on the largest players that we routinely impose on smaller ones. As former Commissioner Stein put it: No firm should be too big to bar

Today the Commission addresses investor protection concerns regarding SPACs with proposed amendments designed to promote transparency and accountability in the SPAC market. My statement: sec.gov/news/speech/le…

Climate change presents momentous risk to financial markets, and investors need to know if and how companies are prepared for it. I’m pleased to support today’s proposal for climate risk disclosures. My statement: sec.gov/news/statement…

Send Lawyers, Guns and Money: see my speech on (over-) zealous representation by corporate lawyers, the case for professional standards, and the unfinished mandate under Sarbanes-Oxley Section 307. sec.gov/news/speech/le…