A new study shows a sharp decrease in enforcement actions by the Securities and Exchange Commission following a change in leadership this year, according to Financial Advisor.
The data compiled by Cornerstone Research and the NYU Pollack Center for Law & Business found that the SEC brought 30% fewer enforcement actions against public companies and subsidiaries in fiscal year 2025 than in fiscal year 2024. The decline coincided with the transition to the Trump Administration and the appointment of Paul Atkins as SEC Chair.
The study noted that former Chair Gary Gensler, who served under President Biden, oversaw 52 actions (93%), while only four were initiated under the new SEC administration—the highest and lowest respective totals for outgoing and incoming chairs during a transition year since at least 2013. In the second half of the fiscal year, the SEC brought only three actions, the lowest half-year total ever recorded in the NYU’s Securities Enforcement Empirical Database. (SEED) The previous low was 19 actions in the second half of fiscal 2017.
After Gensler stepped down in January 2025, Mark Uyeda served as acting chair until April when Atkins was sworn in.
“What’s striking this year is not the overall decline, but when the actions occurred,” said Stephen Choi, a report coauthor and the Bernard Petrie Professor of Law and Business at New York University School of Law and Co-Director of the NYU Pollack Center for Law & Business. “Nearly all of this enforcement activity took place before the SEC administration change, with very few actions under the new administration. Our analysis helps us see the timing and composition of activity in ways that overall totals alone may not reveal.”
Choi said it remains to be seen if the number of cases remains in decline or if the types of cases change after Atkins appointed former military judge Margaret “Meg” Ryan as director of enforcement in September.
“We’ve historically seen declines in enforcement activity during SEC leadership transitions, and FY 2025 aligned with those patterns,” said Sara Gilley, a report coauthor and cohead of the Cornerstone Research securities litigation practice. “Even within that overall decline, the year stood out for its record highs and lows and the unusually low monetary settlements observed.”
The report analyzes information from SEED, which has tracked SEC enforcement actions filed against public companies and subsidiaries since fiscal year 2010. In addition to lower enforcement actions, 2025 also saw lower overall monetary settlements, amounting to $808 million, and the SEC’s February dismissal of its civil action against Coinbase, the first such dismissal in SEED as the SEC re-assessed its approach to cryptocurrency oversight.
Researchers said the stark contrast highlights how little public-company enforcement work occurred after the transition and how heavily the year’s totals reflected priorities under Gensler.
Other patterns found by the researchers were as follows:
-Atkins is expected to focus on disclosure issues. Three of the four actions initiated against public companies and subsidiaries after Gensler’s departure involved Issuer Reporting and Disclosure allegations. This is expected to continue into FY 2026. In May 2025, Atkins signaled his administration would “return” to the “core mission that Congress set” for the SEC—prioritizing “protecting investors; furthering capital formation; and safeguarding fair, orderly, and efficient markets.”
-The SEC initiated 9 actions in January as part of Gensler’s off-channel communications sweep—an area that Atkins indicated interest in addressing in remarks made in October 2025.
-The SEC noted cooperation by 73% of public company and subsidiary defendants that settled in fiscal year 2025, higher than the 2016–2024 average of 65%, reflecting the SEC’s continued emphasis on cooperation under Gensler.
The NYU database does not capture cases against small RIAs or private broker-dealers. In fiscal 2025, actions involving RIAs and investment companies represented 27% of the public-company actions reviewed. Broker-dealer cases accounted for 23%. Issuer reporting and disclosure allegations made up 41%.
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