Parties settling with the SEC pursuant to an administrative order have always been mindful of the collateral consequences that such settlements can have on private litigation arising out of the same facts. The impact of SEC enforcement on private litigation in general is significant—civil cases arising out of the same facts as an SEC action typically settle for higher amounts than cases with no corresponding SEC action. Between 2010 and 2019, more than a quarter of securities class action settlements had a corresponding SEC action. Laarni T. Bulan and Laura E. Simmons, Securities Class Action Settlements 2019 Review and Analysis, Cornerstone Research 11 (2020).