On May 23, 2024, at the Securities Enforcement Forum West 2024, Gurbir Grewal, the director of the Division of Enforcement at the U.S. Securities and Exchange Commission (SEC), gave remarks entitled “The Five Principles of Effective Cooperation in SEC Investigations.” In his speech, Grewal reemphasized the SEC’s focus on corporate cooperation during the agency’s investigations, including that companies self-report to the SEC, including before a company knows all the facts.
Despite these recommendations, the SEC’s silence on precisely how that reporting and cooperation will benefit the company continues to create uncertainty.
