SEC Broker-Dealer Violations, Fiscal Year 2020

Enforcement actions charging broker-dealers with sales-practice, supervisory, recordkeeping, or Regulation Best Interest violations.

Broker-dealer violations sit at the intersection of the SEC's sales-practice, supervisory, and recordkeeping enforcement programs, and the category's composition has shifted meaningfully with the phase-in of Regulation Best Interest — a shift that changes both the exposure profile and the resolution-path distribution for firms in this category relative to prior years. Where sales-practice enforcement once turned primarily on suitability, the post-Reg BI record turns on a broader duty-of-care and conflict-disclosure standard, which means firms are now exposed on dimensions — compensation-incentive disclosure, product-recommendation documentation — that were not independently actionable a decade ago.

Duration in broker-dealer matters tracks firm size and case complexity more tightly than in most other SEC categories: sweep-style exams against a cohort of similarly situated firms (a recordkeeping sweep, for example) tend to resolve on a compressed, coordinated timeline because the underlying fact pattern is largely the same across respondents, while individualized sales-practice investigations against a single large firm can run for years given the volume of customer accounts and transactions that must be reviewed. A portfolio of broker-dealer exposure that mixes sweep-driven and individualized matters needs separate duration assumptions for each, not a single blended average.

For insurers writing E&O coverage for broker-dealers, and for funders evaluating a firm's contingent liability from a pending SEC matter, the category mix inside "broker-dealer violations" — supervisory failure versus sales practice versus recordkeeping — changes both the expected penalty band and the collateral-consequence exposure, since supervisory failures more often carry individual accountability for compliance and branch-manager personnel than sweep-driven recordkeeping matters do. That individual-accountability dimension is itself a duration driver, because matters naming individual respondents alongside the firm typically take longer to resolve than firm-only settlements.

Resolution paths in this category skew heavily toward settled administrative proceedings with undertakings — enhanced supervisory procedures, independent compliance consultants — rather than litigated outcomes, which means the practical question for a firm under investigation is less "will we be charged" and more "what remedial structure will the settlement require and how long will independent-consultant oversight run." Criterica Intelligence's regulated outcomes lens is built to separate those two questions and to characterize the undertaking-duration tail specifically, for the compliance, insurance, and capital-allocation decisions that depend on it.

Figures on this page are drawn from official agency publications, cited individually below, and reflect the agency’s own reporting as of the date shown for each figure. They are not Criterica Intelligence model outputs, are not predictions, and are not a measure of any party’s legal exposure or liability. Agencies periodically revise prior-year figures; where a revision is known, both figures are shown with their sources. This page does not constitute legal, investment, or compliance advice.