Overview
- Staff will provide at least four weeks for written responses to Wells notices going forward.
- Enforcement teams are directed to share key investigative materials, including testimony transcripts and core documents, while protecting whistleblower identities.
- Early, pre-Wells engagement is encouraged, with optional white papers to surface legal and factual issues before a formal notice.
- Senior enforcement leadership is expected to meet with defense counsel before recommendations, and Commissioners will receive Wells submissions even if proposed charges change.
- Atkins urged a return to simultaneous Commission consideration of settlement offers and related waiver requests to preserve fairness and context.