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The Impact of the New Commission Cooperation Initiatives – Part I.

Cooperation was a major tenant in the retooling of the SEC's enforcement program. Borrowing heavily from the Department of Justice, the Commission announced proposals to use non-prosecution agreements and deferred prosecution agreements to encourage cooperation in 2010. While the emphasis was on...

The Impact of the New Commission Cooperation Initiatives – Part II

The SEC's new cooperation tools have impacted a number of actions. In four cases, as discussed in Part I of this article, the Commission entered into agreements under which it either chose to prosecute or deferred prosecution with a view toward dismissal. In most instances where the agency has acknowledged...