Analysis

The Securities Enforcement Empirical Database (SEED) currently provides data for SEC actions initiated against public companies traded on major U.S. exchanges and their subsidiaries. We define public companies as companies with security prices that are tracked by the Center for Research in Security Prices.

The SEC filed 80 new enforcement actions against public companies and subsidiaries in FY 2024, a decrease of 12 percent from FY 2023.   

Public Company and Subsidiary Actions (FY 2015–FY 2024)

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SEED tracks the type of allegation the SEC makes in each enforcement proceeding. In FY 2024, Issuer Reporting and Disclosure allegations were the most common allegation type (41 percent) of all actions filed against public companies and subsidiaries.  Broker Dealer allegations were the second most common action, accounting for 29 percent of the actions filed. 

Heat Map of Allegations Against Public Companies and Subsidiaries (FY 2015–FY 2024)

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In FY 2024, the SEC noted cooperation by 75 percent of public company and subsidiary defendants, the highest level since FY 2019. Of the cooperating defendants that settled, 5% had no monetary settlements imposed.

Public Company and Subsidiary Defendants—Monetary Settlements and Cooperation Noted (FY 2015– FY 2024)

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Monetary settlements imposed in public company and subsidiary actions totaled $1.5 billion in FY 2024, $0.2 billion more than in FY 2023. The median monetary settlement decreased to $3.2 million in FY 2024, lower than the median of $4.0 million in FY 2023.

Monetary Settlements Imposed in Public Company and Subsidiary Actions (FY 2015–FY 2024)

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Disgorgement and prejudgment interest in civil actions, as a percentage of total monetary settlements imposed in public company and subsidiary actions, was 15 percent in FY 2024, the highest percentage since FY 2020.

Breakdown of Total Monetary Settlements Imposed in Public Company and Subsidiary Actions (FY 2015–FY 2024)

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SEED also includes data on admissions of guilt. SEED considers a defendant to have an admission of guilt if the admission is in the SEC action, as opposed to a parallel action. In FY 2024, there were 34 public company or subsidiary defendants with admissions of guilt, the highest number in a FY in SEED. All of the admissions of guilt were in actions in which defendants admitted to recordkeeping failures.

Public Company and Subsidiary Defendants—Admission of Guilt (FY 2015–2024)

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