Key Findings

  • According to a report released this week by New York University's Pollack Center for Law and Business and Cornerstone Research, the U.S. Securities and Exchange Commission (SEC) broughtenforcement actionsagainst public companies in fiscal year 2025 (ending September 30), a 30% decrease year-over-year. Cornerstone Research is an economic consulting firm.
  • The report shows that of the 56 enforcement actions,93% (or 52 actions)occurred during Gary Gensler's tenure as SEC Chair. Gensler stepped down in January 2025, after which Donald Trump began his second term and appointed Mark Uyeda as acting chair until Paul Atkins was sworn in as the current chair in April.
  • Although this downward trend aligns with typical fluctuations during SEC leadership transition years, the report notes that fiscal year 2025 also marked the highest number of enforcement actions under a departing chair since 2013, and the lowest under a new chair. Report co-author and NYU law professor Stephen Choi said in an interview: "The important message here is that enforcement actions under Chair Atkins have been far lower than in any previous transition period. We need to see whether this is just a transitional phenomenon or a longer-term trend."

Deeper Analysis

Even before Trump took office, many securities lawyers and former SEC staff anticipated that an SEC led by Atkins would adoptmore targeted enforcement and more moderate, collaborative rulemaking, as CFO Dive previously reported.

But Choi said that interpreting trends based on less than a year of data under the new administration is akin to "reading tea leaves." Only after Atkins has led the SEC for a full fiscal year can a clearer picture of his true enforcement policies emerge.

Choi noted that there could be several potential reasons for the decline in enforcement actions: the transition process may have caused particular disruption; the surge in cases during Gensler's tenure may have temporarily depleted the enforcement pipeline. Choi added: "And of course there's a third possibility—enforcement is not a priority for Chair Atkins. It's hard to tell right now."

The report also found that total monetary settlements in fiscal year 2025 fell 45% year-over-year to $808 million, the lowest level in over a decade.

The report shows that all four enforcement actions overseen by Atkins involved issuer reporting and disclosure deficiencies. In contrast, Gensler initiated nine enforcement actions in January 2025 targeting "off-channel" communications issues at financial firms.

An SEC spokesperson declined to comment.