Amid the SEC’s slowdown in enforcement actions, CFOs need to tread carefully

There’s a new sheriff in town—and he sure seems to be a fan of deregulation.

As leadership shifted at the Securities and Exchange Commission last year—from outgoing Chair Gary Gensler to Acting Chair Mark Uyeda and now Chair Paul Atkins—enforcement actions fell dramatically.

There were 56 enforcement actions taken against public companies in fiscal 2025, per analysis of SEC enforcement activity from the NYU Pollack Center for Law & Business and Cornerstone Research, only four of which were taken after Uyeda and Atkins took over. That amounted to “the lowest number of actions initiated by a new SEC administration during its first fiscal year since at least FY 2013,” the report said.

“There’s no question that from the enforcement perspective, there was a precipitous drop,” Ben Schiffrin, director of securities policy at Better Markets, a nonprofit that advocates for Wall Street regulation, told CFO Brew.

But even if 2025 is a snapshot of the remainder of Atkins’s tenure as SEC chair, it doesn’t mean CFOs should take a reduction in regulatory burdens to mean total free rein. Securities experts recommend a measured and cautious approach.

The long game. Schiffrin and Lisa Bragança, a former SEC branch chief who now leads a securities defense law firm, have the same general message of caution for CFOs: SEC chair tenures are short; statutes of limitation are long.

Though Atkins has voiced a desire to “future-proof” his policies, and expressed dismay with the general trend of regulatory priorities swinging with presidential administrations, planning as if Atkins’s policy approach will last forever is a bad idea, Schiffrin and Bragança agreed.

“Tread carefully,” Bragança told us, addressing CFOs. “Don’t jump to conclude that just because something has changed at the SEC level, that it means you should move to that disclosure regime. You may still have obligations under state [rules] and other organizations.”

“This is a time that CFOs definitely need to be careful…to make sure that they don’t just go ‘Whee!’” she added. “It’s a more complicated time, because we will have these different views of what needs to be done, disclosed, and what a fiduciary is required to do.”

Similarly, Schiffrin stresses that “enforcement priorities can change.”

“Just because the SEC isn’t bringing cases, it’s not like amnesty,” he continued. “It’s not like you don’t have to do that, and if you don’t do it, you will forever be assured of not being pursued by the SEC.”

State of mind. In the years to come, Bragança thinks it’s possible that while federal regulation ebbs, state-by-state regulation will increasingly come into focus, with states stepping in to take a potentially more rigorous approach.

“Typically, state regulators defer to what the Feds are doing,” she said. “It’s not clear that that’s going to be the paradigm this coming year or in the coming years.”

“I do wonder if states will step into the void, so to speak,” Schiffrin added. “There are areas in which [state regulators] may see the SEC stepping back, but [states] may think that you need greater enforcement in some areas.”

“You cannot just look at what is going on at the very top, at the federal level,” Bragança said. Even in the most extreme what-if cases—like, say, the president saying fraud cases are fully a thing of the past—“that would not change the states, and it would not change the requirements that apply to CFOs as accountants,” Bragança noted.

“Maybe in a decade, the states will follow, and all the other organizations will be in perfect sync with a new regulatory regime from the federal government,” she acknowledged. “But usually these things happen more slowly, and there is more time for consensus and then you don’t have those discontinuities.”

Watching the watchdogs. Still, there are short-term challenges to navigate. For instance, in the nearer term, enforcement alternatives, like the Public Company Accounting Oversight Board, might be strained. The approved budget cuts at the PCAOB, for example, could have ramifications “down the chain, so to speak,” Schiffrin said. “If auditors aren’t being properly monitored, that could lead to companies engaging in more financial shenanigans.”

“As the effects at the PCAOB are felt from this dramatic reduction in its budget, you can see that having ramifications down the chain, so to speak,” he said. (The personnel revamp at the PCAOB was announced after CFO Brew spoke with him and Bragança.)

For CFOs, it’s crucial to follow potential shifts in the regulatory landscape “down the chain,” as Schiffrin put it. Even changes that seem like they’d be far off, like a Trump-proposed rule to make quarterly reports a semiannual practice, shouldn’t be ignored by CFOs.

“Scaling back from quarterly reporting would be a sea change,” Schiffrin said. The key, like so much of sitting in the top finance seat in 2026, is about simply considering the possibility of a regulatory landscape in flux, and preparing where you can.