SEC Announces Enforcement Division Director Judge Margaret A. Ryan Has Resigned From Agency

Key dates

February 11, 2026

- Director Ryan delivered public remarks outlining enforcement priorities and Wells process commitments

February 24, 2026

- SEC announced comprehensive updates to Enforcement Manual (first update since 2017)

March 17, 2026

- Judge Margaret A. Ryan's resignation announced; Sam Waldon named Acting Director (effective immediately)

Ongoing

- Four-week timeline for post-Wells meetings with senior leadership remains in effect pending Acting Director's confirmation of policy continuity

Suggested considerations

• *Immediate (Next 30 Days):
• *Monitor Acting Director's statements: Compliance teams should closely track any public remarks or guidance from Acting Director Sam Waldon regarding enforcement priorities and procedural expectations.
• *Assess Wells submissions in progress: For entities with pending Wells submissions, evaluate whether the change in leadership creates opportunities to supplement submissions or request expedited meetings under the four-week timeline.
• *Review investigation status: Entities in early-stage investigations should assess whether the leadership transition may affect investigation trajectory or resolution opportunities.
• *Update compliance calendars: Ensure all enforcement-related deadlines and procedural requirements under the updated Enforcement Manual remain tracked and current.
• *Medium-term (30-90 Days):

What changed

• The resignation itself does not constitute a regulatory change, but it creates operational uncertainty regarding the enforcement priorities and procedural reforms that Director Ryan had recently implemented: Previously Announced Priorities (Now in Q
• Reduced enforcement for technical violations: Director Ryan had signaled that routine violations concerning reporting requirements, recordkeeping, and internal accounting controls should not necessarily result in enforcement actions.
• "Middle ground" approach: For non-fraud violations posing investor or market integrity risks, the Division was to pursue resolutions emphasizing remediation over punishment.
• Continued fraud focus: The Division was to maintain rigorous enforcement on fraud, insider trading, market manipulation, and scams targeting retail investors. Enforcement Manual Updates (Effective February 24, 2026):
• Four-week timeline for post-Wells meetings with senior leadership (Associate Director level or above)
• Centralized decision-making on criminal referrals at Associate Director or Unit Chief level or above

Who is affected

• Public companies
• Investment advisers and broker-dealers
• Issuers and underwriters
• Corporate insiders and trading participants
• Compliance and legal departments
• Defense counsel
• Audit and accounting firms
• stage investigations, as the Acting Director's enforcement philosophy may differ from Director Ryan's stated approach.

Related regulations

• *Director Ryan's Enforcement Philosophy (February 2026)
• *Enforcement Manual Updates (February 24, 2026)
• Wells process enhancement:
• Centralized decision-making:
• Standardization:
• making in the Office of the Director"3