SEC Regional Offices

56 Pages Posted: 7 Jul 2022

See all articles by Giovanni Patti

Giovanni Patti

NYU Pollack Center for Law & Business

Peter Robau

NYU Pollack Center for Law & Business

Date Written: April 3, 2022

Abstract

In recent years, scholars of federalism and administrative law have identified “regional” variations in how administrative agencies implement policies, as staff in regional offices translate and enforce national rules to reflect local norms. A growing number of legal scholars consider federal regions to
be promising sites to mediate between national administration, on the one hand, and state and local governance, on the other.

Drawing from a novel data set and qualitative sources, this Article contributes to this literature by surfacing the historical and contemporary enforcement work of the regional offices of the U.S. Securities and Exchange Commission (“SEC”). The SEC—consistent with leading examples in the literature—is not a monolith. SEC regional offices today, as they have historically, vary in how they investigate and enforce violations of the federal securities laws across the different geographic areas of the country.

Our data of SEC regional offices’ securities enforcement (FY 2010–FY 2020), however, suggests a more nuanced role for the regional offices than is typically found in the literature: today, geography does not necessarily determine which SEC office investigates or enforces a particular matter. A range of hypotheses might explain this geographic detachment, including advances in technology. In particular, however, we consider structural changes implemented recently by the SEC—including a matrix-reporting structure—which empowered SEC regional offices to develop specialized subject matter expertise. In short, SEC regional offices today may act not merely as local monitors but also as dispersed laboratories for theories of securities enforcement, with implications not only for improved securities enforcement, but, more broadly, regional administration.

Keywords: Regional office, securities enforcement, U.S. Securities and Exchange Commission

JEL Classification: K22

Suggested Citation

Patti, Giovanni and Robau, Peter, SEC Regional Offices (April 3, 2022). New York University Journal of Law and Business, Vol. 18, No. 2, 2022, Available at SSRN: https://ssrn.com/abstract=4129383

Giovanni Patti (Contact Author)

NYU Pollack Center for Law & Business ( email )

139 MacDougal Street
Wilf Hall
New York, NY 10012
United States

Peter Robau

NYU Pollack Center for Law & Business ( email )

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