John Coates, John C. Coffee, Jr., James D. Cox, Merritt B. Fox and Joel Seligman

Shadow SEC Statement No. 7: Too Much, Too Fast

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We concur with the view of SEC Chair Paul Atkins that the SEC has a three-fold mission as enunciated by Congress in the Securities Exchange Act: Protecting investors, furthering capital formation, and safeguarding fair, orderly, and efficient markets. We also …

Shadow SEC: The PCAOB Should Be Carefully Reviewed, Not Hastily Abolished

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We write in opposition to the hasty and opaque efforts underway to abolish the Public Company Accounting Oversight Board (PCAOB), the nonprofit organization that oversees audits of public companies and SEC-registered brokers and dealers in the United States, currently overseen …

Shadow SEC: FCPA Books and Records Requirements Must Be Vigorously Enforced

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President Trump signed on February 10 an executive order (the “Executive Order”)[1] directing the U.S. Attorney General over the next 180 days to (i) review the guidelines and policies governing investigations and enforcement actions under the Foreign Corrupt Practices …

Shadow SEC Statement No. 2 (March 13, 2025): THE CRISIS DEEPENS AS SEC STAFF AND BUDGET CUTS ARE DIRECTED

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With growing concern, we fear that we are watching the SEC face a death by 1,000 cuts. No, we do not mean that the SEC is likely to be abolished by either executive or legislative action (although the Department of …