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SEC Cooperation is Still More Art Than Science


The quest for individual cooperation credit from the U.S. Securities and Exchange Commission is more of an art than a science, involving outcomes based largely on subjective judgments and a process that resists definition and standardization. Indeed, those who seek cooperation credit necessarily take a risk. But that risk comes with the tantalizing prospect of significant rewards — namely, the possibility of avoiding the SEC’s increasingly aggressive enforcement efforts.

Originally published in Law360; reprinted with permission.