August 21, 2026
Client Alert: The SEC Rewrote Its Enforcement Manual. Your Response Playbook Is Now Out of Date.
On February 24, 2026, the SEC released a sweeping overhaul of its Enforcement Manual, the internal guide that dictates how the Division of Enforcement conducts an investigation from initial contact through the Wells process and resolution. Manual revisions rarely make news. This one deserves it. Together with the Commission’s March 2025 decision to reclaim control over formal investigative orders, the new Manual changes the practical rules of engagement for any broker-dealer, investment adviser or associated person who receives a call, a letter or a subpoena from the staff. The majority of these changes tilt in favor of the defense, but only for those who recognize the opportunity and act on it.