SEC enforcement actions: 2022 SEC comment letter trends

In each episode of our 2022 SEC comment letter trends series, our guests bring you the latest themes in comment letters from the SEC’s Division of Corporation Finance.

To conclude the series, this week Heather Horn sat down with Pete Driscoll, a partner in PwC’s National Office, to discuss trends noted in SEC enforcement actions this year, including the increase in cases related to topics on the SEC’s current agenda, such as ESG and cybersecurity.

In this episode, you’ll hear discussion of:

• 1:43 - An overview of the SEC enforcement division and its current priorities 
• 4:43 - Noteworthy enforcement actions related to ESG
• 8:56 - Cases based on false and misleading claims and the types of monetary or disgorgement penalties issued
• 15:05 - The continuing enforcement of traditional cases against issuers, including restatements and cases for inaccurate books and records
• 19:57 - Recent SEC proposals (covered in our publication, SEC proposes new cybersecurity disclosure requirements) and enforcement actions related to cybersecurity
• 21:47 - Advice for listeners as they prepare for year-end reporting

Want to learn more? Check out our analysis of SEC comment letter trends. For additional information on recent enforcement actions, read our alert on the delay in enforcement on Rule 144A securities.

Pete Driscoll is a partner in PwC’s National Office focusing on SEC regulations, reporting, and compliance. Prior to his role at PwC, Pete held several roles at the SEC, including Director of the Division of Examinations and Chief Risk and Strategy Officer.

Heather Horn is PwC’s National Office thought leader, responsible for developing our communications strategy and conveying firm positions on accounting and financial reporting matters. She is the engaging host of PwC’s accounting and reporting weekly podcast and quarterly webcast series. With over 30 years of experience, Heather’s accounting and auditing expertise includes financial instruments and rate-regulated accounting.

Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to us_podcast@pwc.com.