Despite critics who have challenged the legality of the process, the U.S. Securities and Exchange Commission filed every public company enforcement action in the first half of fiscal 2019 as an administrative proceeding, according to a new report.

The report, “SEC Enforcement Activity: Public Companies and Subsidiaries—Midyear FY 2019 Update,” was released Wednesday by the New York University Pollack Center for Law & Business and Cornerstone Research.

Law professor Stephen Choi, director of the Pollack Center and co-author of the report, told Corporate Counsel it's the first time at least since 2010, when the center began its SEC records database, that 100% of the SEC's actions were brought before an administrative proceeding. By comparison, in 2010 only 32% were administrative rather than filed in court.