Trends in SEC ALJ Enforcement Actions and Appeals


There have been a total of 208 Securities and Exchange Commission Administrative Law Judge actions since 2013, including 49 in 2016, according to Bloomberg Law data.

The 49 actions last year were down from the 62 and 61 actions in 2014 and 2015, respectively.

Over the last four years, 2013 saw the least number of actions with 36.

ALJ Appeals 2016

Out of the 49 actions brought in the last year, only 11 were appealed to the commission. This is down from the 15 appeals filed in 2015.

Because the appeals process can be costly and time-consuming, and respondents risk more severe sanctions resulting from the SEC’s de novo review, appeals to the commission remain rare.

For more analysis of Bloomberg Law's 2016 ALJ data, check out Number of SEC In-House Decisions Still Sliding, 2016 Stats Show.

For more information on trends in SEC ALJ enforcement, Bloomberg Law subscribers can access the SEC ALJ Enforcement Tracker and SEC ALJ Enforcement Analytics.