One of the Commission’s most effective deterrents against future misconduct is what it says about the enforcement actions it takes. As a result, the Commission must use its position as a regulatory authority to carefully and effectively send clear messages to securities industry participants regarding what is, and what is not, acceptable behavior. For this reason, Commission Orders need to contain sufficiently detailed facts so that there is no doubt as to why the Commission brought an enforcement action, why the respondent deserved to be sanctioned, and why the Commission imposed the sanctions it did.
Tate comment: click on the following link for the speech – I would argue that SEC enforcement orders should be more detailed anyway so that they clearly justify the position that the SEC is taking: www.sec.gov
Tate’s Excellent Audit Committee Guide updated August 7, 2015 (122 pages) CLICK HERE.