93% of FY 2025 actions were filed before the SEC administration change.
The U.S. Securities and Exchange Commission (SEC) brought 30% fewer enforcement actions against public companies and subsidiaries in FY 2025 than in FY 2024—a decline that coincided with the change in SEC administration. The findings, presented in the SEC Enforcement Activity: Public Companies and Subsidiaries—Fiscal Year 2025 Update released today by Cornerstone Research and the NYU Pollack Center for Law & Business, are based on SEC data available as of November 14, 2025.
Nearly all of this enforcement activity took place before the SEC administration change, with very few actions under the new administration.
While a decline aligns with previous years in which there was an SEC administration change, FY 2025 stood out for its composition: outgoing Chair Gary Gensler oversaw 52 actions (93%), while only four were initiated under the new SEC administration—the highest and lowest respective totals for outgoing and incoming chairs during a transition year since at least FY 2013. After Chair Gensler stepped down in January 2025, Mark Uyeda served as acting chair until April when Chair Paul Atkins was sworn in.
“What’s striking this year is not the overall decline, but when the actions occurred,” said Stephen Choi, a report coauthor and the Bernard Petrie Professor of Law and Business at New York University School of Law and Co-Director of the NYU Pollack Center for Law & Business. “Nearly all of this enforcement activity took place before the SEC administration change, with very few actions under the new administration. Our analysis helps us see the timing and composition of activity in ways that overall totals alone may not reveal.”
Our analysis helps us see the timing and composition of activity in ways that overall totals alone may not reveal.
“We’ve historically seen declines in enforcement activity during SEC leadership transitions, and FY 2025 aligned with those patterns,” said Sara Gilley, a report coauthor and cohead of the Cornerstone Research securities litigation practice. “Even within that overall decline, the year stood out for its record highs and lows and the unusually low monetary settlements observed.”
This year stood out for its record highs and lows and the unusually low monetary settlements observed.
The report analyzes information from the Securities Enforcement Empirical Database (SEED), which has tracked SEC enforcement actions filed against public companies and subsidiaries since FY 2010—a period that has seen four changes in SEC administrations. In addition to record activity levels, FY 2025 was notable for lower overall monetary settlements—$808 million, the lowest for any year in which there was an SEC administration change and the second lowest for any year in SEED. FY 2025 also included the SEC’s February 2025 dismissal of its civil action against Coinbase, the first such dismissal in SEED amid the agency’s ongoing reassessment of its approach to cryptocurrency oversight.