In a new article published by Law360, Brattle Senior Associates Adrienna Huffman and Erik Johannesson and Principal Jan Jindra analyze changes in the US Securities and Exchange Commission (SEC)’s enforcement docket during the third quarter of the 2026 fiscal year. The article builds on an April 2026 Brattle report examining SEC enforcement activity during the first half of FY26.

In “Q3 Numbers Refine Picture of SEC Enforcement Trajectory,” the authors find that enforcement activity remained relatively quiet in the third quarter, reinforcing the case that the slowdown that began in 2025 may reflect more than a temporary transition between administrations. However, estimated Q3 enforcement activity showed a slight rebound from the same period in the 2025 fiscal year.

While the overall estimated case volume remains below historical levels, case types have shifted significantly in Q3. Investment adviser and securities offering cases continued to make up a large portion of the docket, while insider trading matters rose sharply. The article also assesses new Commission initiatives and highlights areas to watch in Q4.

Key takeaways from the article include:

The SEC announced new initiatives targeting retail fraud and financial reporting.
Increased insider trading cases and new SEC initiatives point to a more concentrated docket centered on fraud, individual misconduct, market abuse, and demonstrable investor harm.
September has historically been the SEC’s busiest filing month, meaning a substantial increase in enforcement activity remains possible in Q4.

Read the full article below.

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