2019 was a remarkable year in the securities regulatory and enforcement space. In this episode of inSecurities we’ll break down record enforcement results, vigorous dissents to rulemaking packages and legislative fixes to thorny legal issues.





[00:00:00.00] SPEAKER: This program is brought to you by the Practising Law Institute, a nonprofit learning organization dedicated to keeping attorneys, professionals, and accountants at the forefront of knowledge and expertise.

[00:00:14.78] KURT WOLFE: Record enforcement results, vigorous dissents to rule making packages, legislative fixes to thorny legal issues. 2019 was a remarkable year in the securities regulatory and enforcement space. We're going to break it down for you today on the inSecurities podcast.

[00:00:39.71] CHRIS EKIMOFF: Hello, and welcome to inSecurities, a new podcast from PLI, the Practising Law Institute. I'm Chris Ekimoff, and I'm here as always with my co-host, Kurt Wolfe.

[00:00:49.10] KURT WOLFE: Good to be with you, Chris.

[00:00:50.81] CHRIS EKIMOFF: On each episode of the podcast we'll get you up to speed on hot topics and trends in the securities regulatory world. Offering a practitioner's perspective on the rules, regs, and cases you should be following. To kick off the series, we thought it would be helpful to spend a couple of episodes thinking at a high level about what's happening in the securities regulatory space.

[00:01:08.76] So over the next two episodes, we're going to take a look back at what happened in 2019, and peek around the corner to give you a sense of what to expect in 2020.

[00:01:18.53] KURT WOLFE: This week, we're going to break down our top five securities and regulatory enforcement developments from 2019, including top level FCC enforcement trends, FCC rule making, blockbuster cases, new or proposed securities legislation, and my personal favorite, everybody don't hold your breath, some key accounting developments.

[00:01:36.89] CHRIS EKIMOFF: We can't wait to get there.

[00:01:38.45] KURT WOLFE: As I said at the top, Chris, it was an interesting year in the securities regulatory and enforcement space, and there's a lot to talk about. So let's jump into it.

[00:01:55.98] The Securities and Exchange Commission's Division of Enforcement had a banner year in 2019 according to its annual report, the enforcement division brought 862 enforcement actions in fiscal year 2019, the second highest tally ever. And obtained judgments and orders totaling more than 4.3 billion in disgorgement and penalties, the most ever.

[00:02:15.81] By any measure, we believe the division had a very successful year, said the SEC's co-directors of enforcement Stephanie Avakian and Steve Peikin. Still, the co-director would prefer the observers not focus on the numbers, but on the qualitative factors, such as the nature, quality, and diversity of the SEC enforcement actions, and the impact of those actions on the behavior of market participants and the overall integrity of our markets.

[00:02:39.59] CHRIS EKIMOFF: Kurt, looking at the cases, what were your key takeaways from the 2019 year in securities enforcement?

[00:02:44.78] KURT WOLFE: There were several, Chris. I mean, first I actually do want to talk about the numbers a little bit because I think the numbers matter. At least in so far as they tell us a little bit about the division's priorities. And I think they are a barometer to gauge the strength of the program overall. And quite frankly, in fiscal 2019, the figures were impressive. It was a short year. If you recall, there was a 35 day government shutdown to start the year. So they achieved their second best and best ever results in an 11 month year.

[00:03:18.87] They were also short staffed due to lingering effects of a prolonged hiring freeze that was lifted in 2019. And they did all of this in the face of some recent Supreme Court rulings that imposed restrictions on how the enforcement staff can go about its business, which forums they can use to resolve SEC enforcement matters, and how quickly they need to move.

[00:03:40.05] So despite some challenges, they had a really strong year statistically, and I do think it's worth noting. But to the co-directors point, I think if we look past the numbers and think a little bit about what was the actual case mix and what does that mean, a few things jumped out.

[00:03:58.86] First for me is that the commission's focus on retail investors is real, and they are committed to it. During their tenure, the co-directors have consistently talked about protecting Main Street investors. Every year, it's among their top five priorities. And this year was no different.

[00:04:17.50] I think what we're seeing is that, from an enforcement perspective, there is an increasing focus on investment advisory firms and broker dealers and other financial services firms and professionals that regularly interact with retail investors. And the numbers bear this out. In total, the division brought 191 standalone cases against investment advisors or investment companies in fiscal 2019. That was a record number of cases against investment advisors, and far and away the largest bucket of cases in the year.

[00:04:49.62] The division also brought 38 standalone cases against broker dealers. And together, the cases against investment advisors and broker dealers comprised 43% of the division's entire caseload.

[00:05:00.30] CHRIS EKIMOFF: So not only are they breaking records at the top line in terms of total cases and total disgorgement of penalties, it also seems like this focus on retail investors is bringing it to, for lack of a better phrase, bringing it to the street to the Main Street investors out there.

[00:05:13.14] KURT WOLFE: Absolutely right. And I think we should expect that to continue into 2020 and beyond. In terms of this being a topic of programmatic significance for the enforcement division, that's not going anywhere. And I think the focus on investment advisory firms is going to continue.

[00:05:31.84] CHRIS EKIMOFF: Talk to me a bit about what settlements look like in 2019.

[00:05:34.15] KURT WOLFE: Yeah, so I think you have to dig into the numbers a little bit here, but I think it's an important enforcement trend. It appears to be the case that settlement figures are inching up. As we've mentioned, in fiscal 2019, the division obtained the highest amount ever or ordered the highest amount ever of disgorgement and penalties. This is interesting in an environment where the co-directors have spoken repeatedly about their desire to tailor penalties and disgorgement more carefully to the misconduct at issue or other factors, such as self-reporting, cooperation, remediation.

[00:06:12.54] And so there seems to be a little bit of an incongruity between the principle of imposing only remedies that further the division's enforcement goals, and simultaneously ordering penalties that led to a record setting year. I think that we can resolve that as follows. Even if the division is, in fact, considering tailored or alternate remedies in some matters, settlement demands seem to be inching up across the board.

[00:06:40.94] The numbers that you can find in the annual report would seem to support this. Indeed, according to the report in fiscal 2019, the median disgorgement ordered, penalties ordered, and total money ordered, those are buckets that are set out in the report. Each of those buckets met or set records. And in fact, the median total money order, the median total money ordered in 2019 was 52% higher than fiscal 2018. And 11% higher than the second highest figure ever reported.

[00:07:16.22] CHRIS EKIMOFF: Those are big results.

[00:07:18.29] KURT WOLFE: Yeah, they're big results. And I think it's an important trend to watch. I think, Chris, you and I have talked offline a little bit about how the mix is evolving in terms of settlement figures. I think what we saw here this year, there wasn't one or two or three massive cases that sort of exploded the total amount of disgorgement and penalties recorded. Instead, I do think we're watching this median number creep up, which means if you are a regulated firm or a publicly traded company that is regulated by the SEC, and you find yourself in the cross hairs of an SEC enforcement staffer, you might reasonably expect that it's going to cost a little bit more to settle a case than it would have 5 or 10 years ago.

[00:08:07.73] Chris, did you know that many of these topics are covered by PLI's on demand programming?

[00:08:12.68] CHRIS EKIMOFF: I did. Many of these issues, and more, are covered by the authoritative programming produced by PLI, an 80-year-old nonprofit, established to help keep legal professionals up to date on changes to the law.

[00:08:23.03] KURT WOLFE: And make sure to check out PLI's SEC Institute, the leading provider of SEC compliance and accounting education, CLE, and CPE credit is available on PLI.edu.

[00:08:35.96] CHRIS EKIMOFF: Start 2020 well, and get your CLE and CPE taken care of with PLI.

[00:08:44.06] Switching up a bit, Kurt, not that the annual report from the enforcement division isn't riveting, talk to me a bit about some of the rule making initiatives with the SEC in 2019.

[00:08:51.77] KURT WOLFE: Yeah, so I mean, 2019 is not all about enforcement. It was, in fact, a very busy year from a rule making perspective for the SEC. And so just want to focus on that for a couple of minutes. In 2019, the SEC proposed about 40 new rules, and they finalized about 20 new rules, in addition to several interpretive and concept releases. Those things run the gamut from proprietary trading to solicitation rules to FOIA regulations, capital and margin requirements, and just recently proposed rule around the accredited investor definition, which is a controversial rule that we're going to have to wait and see how that plays out. I think it's something we'll be talking about throughout 2020.

[00:09:38.78] CHRIS EKIMOFF: Could be very impactful.

[00:09:40.31] KURT WOLFE: Absolutely. Absolutely could be. And it's interesting how that definition plays in with some of the other rule making.

[00:09:47.21] [INTERPOSING VOICES]

[00:09:47.56] Proposed rule makings that the SEC has laid out over the past several months.

[00:09:51.42] I want to just touch on two, for purposes of our conversation today, that I think are likely to be the most impactful, and have been two, perhaps, of the more controversial or at least most noteworthy. The first is regulation best interests, which the SEC approved in June.

[00:10:09.86] Essentially, Reg BI, as it's called, builds on [INAUDIBLE] obligation to make only suitable recommendations to retail investors by requiring that broker dealers also act in the best interest of their retail customers. At the same time that best interest was adopted, the SEC also issued an interpretive release that clarifies the standard of conduct that is required of investment advisors when they give investment advice to their clients.

[00:10:39.49] They also issued a rule that would require that firms provide a new form CRS, or client relationship summary, which is designed to help principally retail investors understand better the relationship between themselves and their financial services professional. Whether that person is an investment advisor or a broker dealer. form CRS will tell them things about the duty that is owed to the investor or the types of fees that can be charged.

[00:11:08.16] Reg BI was, and continues to be, pretty controversial because it did not do what some folks in the industry wanted, which was require broker dealers to satisfy a fiduciary standard of conduct when they provide investment advice, or recommendations in the case of a broker dealer, to investors. There are many folks in the market who thought it would be easier if you just brought the broker dealer standard up to a fiduciary standard to match the standard that is required of investment advisors instead of having this sort of dual track.

[00:11:46.29] Because now, dual registered firms have to figure out, in some cases, when am I acting as a broker, when am I acting as an investment advisor. On the back end of this, there have been lawsuits attempting to set aside Reg BI. There are a number of states securities regulators and state legislatures that have drafted, or are considering implementing, their own standards of conduct for broker dealers.

[00:12:12.27] The CFP board set out, this year, a new standard of conduct for its registered professionals or its members that would require them, in any circumstance, to observe a fiduciary conduct standard.

[00:12:25.68] So this is very much an evolving space. As it stands, it looks like Reg BI is going to go into effect, the compliance deadline is June 30, and firms should already be thinking about building a compliance framework around Reg BI, or any more restrictive rules or regulations that apply to the firm.

[00:12:44.43] CHRIS EKIMOFF: Sounds like they're teeing up another push to protect retail investors, although it sounds like some in the industry don't think it went far enough.

[00:12:51.15] KURT WOLFE: Absolutely right. And I think that's a through line for everything we're going to talk about today. It's been building over years, but 2019 was definitely a year where we saw a huge push to continue the efforts to protect retail investors.

[00:13:03.98] CHRIS EKIMOFF: You mentioned another rule you wanted to bring up.

[00:13:05.94] KURT WOLFE: So the other one I'll mention-- and this is something we're probably going to talk about again next week, and probably going to talk about it in February-- is the new advertising rule proposal. So this was long overdue. About 60 years overdue, in fact. And the SEC has finally proposed a new rule around investment advisory firms advertising. And it's getting mixed reviews, quite frankly. On the one hand, it's great because it would create a looser definition of advertising.

[00:13:37.77] So that it used to be things like, is it a TV ad or a radio ad, right? But we, obviously, have social media and other new media now through which people tout their investment advisory prowess. This brings all of that under the umbrella.

[00:13:51.15] It also sets out what the SEC would call a principles-based rule. Which instead of being very prescriptive in terms of you must include these disclaimers, or this legend on your marketing materials, now it's more about are these material-- do they include misstatements? How are you presenting things like performance results, right? Very high level.

[00:14:14.16] And there is some question about whether or not existing guidance and no action letters are going to survive, and whether firms can continue to rely on them. So right now, we're in the comment period for this rule. The comment period runs through just about the end of February. And after that, the SEC will go into the final phase of bringing this rule making into a final form that will be voted on. It's going to be an interesting space to watch, and there will definitely be more from us on that.

[00:14:45.00] CHRIS EKIMOFF: That's all great, Kurt. I know that there's been a few names in the news recently related to significant securities enforcement cases. We've got the Kokesh, we've got the Salman, we've got the Lucia. I know you want to talk at least about one case that happened 2019 that was pretty interesting.

[00:14:58.76] KURT WOLFE: Yeah, it's been an interesting time, at least at the Supreme Court if you are an SEC regulatory enforcement lawyer. I mean, over the past few years, there have been more Supreme Court cases involving the SEC or the SEC's regulatory regime than I think there has been in any period like that.

[00:15:16.88] [INTERPOSING VOICES]

[00:15:17.48] Probably ever. Certainly in a long time. So yeah, it's Kokesh, it's Salman, Lucia, Digital Realty, and this year we had another one which was Lorenzo versus the SEC. This is what I like to think of as the copy and paste case.

[00:15:30.92] CHRIS EKIMOFF: That's right.

[00:15:31.28] KURT WOLFE: So there was a case a couple of years ago called Janis that had to do with when does someone quote, make unquote a statement for purposes of SEC regulations. And from an enforcement context, what that really means is when can you be on the hook for making a misstatement? What we dealt with in Lorenzo was an instance where an individual copied and pasted into an email misstatements that were written, or made, by someone else, right?

[00:16:00.68] And so the question was did that person make a misstatement for purposes of the securities laws, such that they could be charged with fraud in an SEC enforcement action. The DC circuit found that the person didn't make a misstatement for purposes of federal securities laws.

[00:16:18.47] SCOTUS turned that around, and they said, in fact, that the person did have the intent to disseminate a misstatement, right? And they went through a somewhat-- I'm thinking of the word tortured, but perhaps I should say detailed analysis of the definitions that are in the regulation to think about when are you making something that is potentially a misstatement.

[00:16:45.62] And then here, I think what they found is that if you are intentionally copying and pasting a misstatement into an email, you can be on the hook for securities fraud.

[00:16:53.36] CHRIS EKIMOFF: So I'm not brushed up on my Latin. We're all familiar with the caveat emptor, buyer beware. This sounds like maker beware, right? If you're the one pasting the statement, be sure that you're up to date on whether it's fraudulent or not.

[00:17:04.79] KURT WOLFE: At least sender beware.

[00:17:06.31] [INTERPOSING VOICES]

[00:17:07.39] CHRIS EKIMOFF: Look up the Latin on a future episode.

[00:17:09.54] KURT WOLFE: Yeah, absolutely.

[00:17:13.52] CHRIS EKIMOFF: So Kurt, we covered the SEC enforcement report. We talked a bit about some of the rule making. We had a big case. What about some of the legislative efforts that have happened in 2019?

[00:17:23.11] KURT WOLFE: Yeah it's been a busy year there, too. Again, 2019 was just interesting, right? And we saw it playing out on the hill as well. I mean, a few things that happened or some still are happening.

[00:17:34.76] First had to do with the appropriations bill, which was actually just passed out of the house. A final version was passed out of the house just days before we recorded this episode. What was interesting was that Reg BI came into the conversation around the appropriations bill.

[00:17:50.51] And in an earlier version, Congresswoman Maxine Waters had included amendments that would restrict the SEC's ability to spend the budget dollars allocated to the commission to implement, enforce, advertise, regulation best interests. It was essentially a way, or an effort, to gut Reg BI.

[00:18:11.42] That got stripped out of the final version of the House Appropriations bill. Interestingly, they plunked in a restriction that says the SEC cannot spend any of its money on a rule making that would require companies to publicly disclose campaign contributions, which is something that Commissioner Jackson has pushed for. But it's just interesting to see how some of these regulatory initiatives or designs become political, and how that plays out in bills. So that was one that happened.

[00:18:41.11] Two other things I'll just mention. One is we've mentioned Kokesh in passing during this podcast. And essentially what Kokesh did was say that, in cases where the SEC seeks a disgorgement remedy, they are subject to a five year statute of limitations. This was met with all kinds of criticism.

[00:19:01.94] CHRIS EKIMOFF: Ground shaking.

[00:19:03.05] KURT WOLFE: I mean, maybe not by the defense bar, right?

[00:19:06.56] [INTERPOSING VOICES]

[00:19:07.47] CHRIS EKIMOFF: Some ground was shaken.

[00:19:08.66] KURT WOLFE: But it got a lot of attention, and there has been much talk about trying to pursue a legislative fix. And so we have that in the form of a bill that was passed in the House by a vote of 314 to 95, right? So we're not seeing a lot of those votes.

[00:19:24.18] [INTERPOSING VOICES]

[00:19:26.37] So a popular bill that would actually do two things. One is it would make clear that the SEC absolutely can seek a disgorgement remedy in federal district court. A question that's the subject of a case we'll talk about in a future pod. And second, it would install a 14 year statute of limitations, which is interesting. Because pre-Kokesh, everybody thought it was 10, right?

[00:19:51.32] So 14 is a little bit random, but that's what this bill would do. Not sure what's going to happen when it goes into the other chamber. But given the broad bipartisan support, I think it's got a shot.

[00:20:05.67] The second one I'll mention, another bill that passed the House. This was by a 410 to 13 vote. So another one with broad support across the aisle is an insider trading bill. And it, essentially, just codifies what is an insider trading violation. It doesn't really upset the apple cart by setting out criteria that are really new or different from what has emerged in the case law over the years.

[00:20:32.97] But there just continue to be cases, right? There was Salman and then there was Martoma, and there was Martoma II, right? It's an evolving case. And what this would do is just put a stop to that in some sense and say, here's the framework. Again, not sure what will happen when that gets to the Senate. But another interesting piece of legislation that we should be following.

[00:20:49.86] CHRIS EKIMOFF: And I'm sure most of the listeners to this podcast know that there is no actual definition of insider trading. But to the layperson, that's often shocking when you see the headlines related to insider trader put away or paying back to the ill-gotten gains. There really is no one textbook or one piece of legislation that defines it, and this seems to be moving in that direction.

[00:21:08.56] KURT WOLFE: Yeah, it's an interesting element of the US federal securities laws, right? If you look in other countries, even our neighbors to the north in Canada, they have a statute that says this is what insider dealing is, OK? And we don't have that. And there have been people like Judge Jed Rakoff, Preet Bharara, Commissioner Jackson, over the past few years, have been pushing to try to get some kind of bill together that would just say, these are the rules of the road.

[00:21:34.95] And maybe we have that now. We'll have to wait and see.

[00:21:41.79] All right, so Chris, I've been doing a lot of talking about a lot of things. We've covered important cases in legislation. We've talked about SEC enforcement trends. I want to know, in 2019, what were the big takeaways in the accounting space?

[00:21:56.30] CHRIS EKIMOFF: We'll continue our conversation in the enforcement space because I don't want to get into all the fun stuff with the CECL rules, which we'll talk about as time goes forward.

[00:22:04.35] Two of the things that

[00:22:05.22] [INTERPOSING VOICES]

[00:22:06.00] That's right. Two of the things that really stuck out from an enforcement perspective were the types of cases being brought, and the diversity of those. And I think it's been pretty consistent from year to year. We're seeing cases brought related to earnings management, revenue recognition, that's happened since time immemorial.

[00:22:21.96] Some of the other new and emerging things that have come in the past few years is the representation of metrics in your disclosures, whether those metrics be gap metrics, generally accepted accounting principles, base metrics, or a term I'm sure most of you listening know, non-GAAP. In which that term is not a gap defined metric, but it's still represented as valuable as a disclosure.

[00:22:40.74] And then, we see the regular cadre of books and records and internal controls violations we'll talk about in a bit, as well as some of the financial disclosure related issues that have happened over the period.

[00:22:51.25] So all in all, run of the mill doesn't sound right for the way that the accounting and auditing enforcement has happened in 2019, but it's good to see that standard being pushed forward and continued on that the commission is putting forth a message for accounts and auditors out there of which ways they're going.

[00:23:06.49] KURT WOLFE: Yeah, I mean, one of the things that I've noticed in the auditing and accounting space relates to private funds. I mean, this has been an area of increasing programmatic significance for the SEC enforcement division over the past several years, really post Dodd-Frank, right? Ever since some of these private fund advisors were required to register with the SEC.

[00:23:26.04] And what I think has become a pretty perennial topic now are valuation issues relating to private funds, or how they value the underlying assets. And I think it's because-- you tell me- but a lot of them use non-GAAP metrics or accounting as part of their valuation methodology. It's something that we're seeing now every year in the enforcement space.

[00:23:48.99] CHRIS EKIMOFF: Yeah, and it's not limited just to evaluations, right? This can be regular financial disclosures as part of your MD&A and your 10-K or Qs, as well as some of the press release and earnings reports you might put out can have these non-GAAP metrics or these hard to follow measures that make it misleading when they're put out there, and obviously the commission is very interested in that.

[00:24:08.92] But it's interesting you bring up the accountants role, Kurt. One of the drumbeats we've heard from the commission over the past 12 months has been the focus on the term gatekeepers. Those individuals who are between the company or the investment advisor and the market, the retail investor or the shareholders. How is that information being portrayed? Is it being reviewed and audited accurately? Are appropriate principles being followed in the administration of that audit?

[00:24:34.82] And that focus on the gatekeeper is something that's grown over the past maybe two or three years. It has really come to the forefront this year, as well as what we're seeing into 2020 related to holding accountants and auditors responsible, both to their own professional standards as well as those regulated by the Commission. And their duty to the client to be sure that they're offering the appropriate amount of information and providing the right amount of scrutiny to make sure that the users of that financial information know what they're getting.

[00:25:02.33] KURT WOLFE: Yeah, gatekeepers is definitely an area that has grown in importance over the past several years. I mean, I think if we think back to maybe three or four or five years ago, we were thinking about something different altogether. And it was often firms that were giving usually non-US people or firms access to the US capital markets.

[00:25:24.12] They were the gatekeeper in the sense that they were the entity or the firm through which someone outside the US was tapping into our markets. We've seen gatekeeper cases involving attorneys where they are providing some kind of advice or maybe standing between a public issuer and the SEC, or between that issuer and the market in terms of reviewing their disclosures or other things.

[00:25:46.80] And I do think that shift or that evolution is just now playing out more in the accounting space, or increasingly over the last couple of years.

[00:25:54.81] CHRIS EKIMOFF: Yeah, and one other key contextual thing to note from the enforcement perspective is the chief accountant for the enforcement division, Matt Jacques, took that job in October of 2018. So he's just now getting into his first full year tenure. And as every enforcement accountant comes along, the profiles and focus change. It seems like this iteration here is really focused on a lot of those issues, and bringing up those cases.

[00:26:18.06] We talked about some of the stats at the top of the pod about the cases brought and the disgorgements and penalties being asked for, being ordered. I think that the longer the tenure of the chief accountant for the enforcement division is, the more focused and successful he may be in doing so.

[00:26:35.16] One final thing to think about as we look at the accounting side, I'm sure many of you have heard this acronym before, CAMS, C- A- M's, critical audit matters. This is a developing area, like some of the other things we've talked about. Was put into its rulemaking process from the AICPA and the PCAOB back, I believe, in 2017, and just became effective in the June of this year.

[00:26:58.38] So large accelerated filers are encouraged, and actually required, to report their critical audit matters. The auditors to report them and their auditor's report. As of any filing after June 30, 2019. And then, that's becoming mandatory for all SEC registrants as of December 15th of 2019. So basically, this will be our first year end cycle on which every auditor's report that we read for those registrants includes a critical audit matter.

[00:27:23.87] It's going to be interesting. There's been some preliminary results on that about what's being reported as a critical audit matter. Revenue recognition is always at the top of the board. There's some questions about leasing and credit losses as well, which are two areas of the accounting world that are still in development.

[00:27:37.88] This will be something we talk about on our next episode related to what we see in 2020 as well. So a big year on the auditor side for that. But we'll be seeing a lot more both filings with critical audit matters involved in them, and potentially some litigation or some questions around what was a critical audit matter and why in cases going forward.

[00:27:56.09] KURT WOLFE: Absolutely. I think, Chris, in future, we're going to have to do an acronyms episode. Just 25 minutes of CAMS, CAT, [? GAT, ?] [? MIDAS, ?] [? MAGIC, ?] whatever else we can come up with, so that maybe, someday, someone will be able to decipher what we're talking.

[00:28:13.43] CHRIS EKIMOFF: It'll probably be our lowest listened to episode in the history of the podcast.

[00:28:16.34] KURT WOLFE: Could be a blockbuster.

[00:28:18.38] CHRIS EKIMOFF: Well, that's our show for today. We covered our top five takeaways from 2019 as it relates to the SEC regulatory and enforcement space. We talked a bit about the trends we saw in 2019. Some of the rule making efforts, including Reg BI. We blew through the Lorenzo case, as it sits at the Supreme Court and the decision it made. We talked through a couple legislative items, and a few accounting developments we saw in 2019.

[00:28:40.97] KURT WOLFE: As we said at the top, it was an interesting year, and it was fun to do a little bit of a retrospective to figure out what things we needed to really take away.

[00:28:49.01] CHRIS EKIMOFF: On the next episode of inSecurities, we're going to look forward. Help you peer around the corner a little bit to figure out what are the securities regulatory and enforcement developments you should keep an eye out for in 2020.

[00:29:00.95] If you're looking for more information about the podcast between episodes, check us out pli.edu/insecurities. You can also find Kurt and me on Twitter. My Twitter handle is ekimoff@cpa.

[00:29:13.07] KURT WOLFE: And I am @enforce_update.

[00:29:16.28] CHRIS EKIMOFF: We'll be using the hashtag insecurities pod to denote any content that we think relates to the podcast. Feel free to follow us. Use the hashtag. Let us know what you'd like to hear from us. We'd be happy to include that in future episodes.

[00:29:28.35] SPEAKER: Thanks for tuning in, everybody. We'll see you next time. Thanks for listening to inSecurities, a podcast from PLI, the Practising Law Institute. PLI is a non-profit provider of authoritative professional services training and continuing education. In an increasingly complex business environment where intricate corporate structures reign, inSecurities can help you make sense of it all.

[00:29:58.59] A special thanks goes to the producer of inSecurities, Daniel Painitz, as well as host Chris Ekimoff and Kurt Wolfe. For more information about PLI's SEC Institute, or to view hundreds of hours of fresh and relevant on demand programming covering changes within the security sector, visit pli.edu/membership and sign up for a privileged membership.

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