There is no doubt that the SEC under current Chair Paul Atkins has taken a different enforcement approach than under the prior administration. The statistics (at least those through the end of the last fiscal year) show a notable decrease in the number of SEC enforcement actions under the Trump administration.  As questions arise about the current administration’s enforcement approach, including whether the agency’s approach might embolden would-be wrongdoers, one particular question has been with respect to the Director of the agency’s Enforcement Division. Observers have asked whether the division director, Margaret “Meg” Ryan, who was nominated to her position last August, is deliberately leading the division in a hands-off approach.

In a February 11, 2026, speech, one of her first public statements since assuming her current position, Ryan specifically addressed many of these concerns. Ryan wants the world to know that agency intends to enforce the federal securities laws, albeit arguably on different terms than may have prevailed in the past.

Background

After graduating from college and prior to attending law school, Ryan served in the United States Marines. After law school, Ryan among other things served as a law clerk for Supreme Court Justice Clarence Thomas. Following her clerkship, she worked in private law practice. In 2006, Ryan was appointed to the United States Court of Appeals for the Armed Forces, a judicial position for which she assumed senior status in 2020.

Ryan delivered her February 11, 2026, speech as part of the Annual Securities Regulation Seminar of the Los Angeles County Bar Association. A copy of her speech can be found here. In her introductory comments, Ryan specifically describer her speech as “her first public remarks.”

The February 11, 2026, Speech

Ryan began her speech by emphasizing how her prior experience in the Marines, as a judicial clerk, and as an appellate judge shaped both her approach to the law generally and her approach to her current position.

Her experience forms what she called her “guiding principles”: that is, “integrity, honor, fidelity to the law, and an unwavering commitment to the fair and judicious use of the formidable power and resources the federal government has entrusted to me.”  She added that she thought these principles “mirror the Chairman’s commitment to upholding the rule of law and ensuring fair process to all those who participate in and benefit from our capital markets.”

In discussing the agency mission, which she described as “protecting investors; maintaining fair, orderly, and efficient markets; and facilitating capital formation,” she emphasized what she called “two primary topics” – process and priorities.

With respect to process, Ryan stated that the Enforcement Division is “committed to providing transparent and appropriate process to individuals and to companies under investigation by Enforcement.” In elaborating on this commitment, Ryan discussed the Wells Notice process, which is designed to afford potential enforcement targets with “fair opportunity to respond.” She added to this observation an admonition to the defense bar “not to mistake fairness for weakness.” She also warned against “deliberate circumvention of the process,” including “tactical tardiness and other games,” which, she advised, “will not be tolerated.”

Ryan then went on to elaborate on the Division’s priorities. First and foremost, she said, the Division “remains focused on its mission to vigorously enforce federal securities laws in accordance with the Chairman’s focus on returning to the basics, with fairness and a focus on timely resolution of case.” She added words of praise for the quality of the Division staff, adding “Fraud on our capital markets persists, and so does my staff as they work to eliminate it.”

Ryan then delivered what is unquestionably the money quote of her speech – she observed that “reports that enforcement work at the SEC has been tossed to the wayside are not only greatly exaggerated but flat out wrong,” adding the acknowledgement that she is “far more concerned with the quality and impact of the enforcement actions that we bring than with chasing numbers.”

Ryan acknowledged further that “I do not have unlimited resources at my disposal,” a fact that ensures that she must “focus on using the resources we have judiciously” – that is, “where they can most effectively and fairly be used to protect investors and our capital markets.” Put simply, she said, “we have focused and will continue to focus on bringing good cases that further the SEC’s core mission.”

Ryan went on to say that “a principal focus of our enforcement program” is to “protect investors from the myriad fraud schemes cooked up by bad actors,” particularly those “that inflict devastating costs on everyday retail investors,” fighting which, she said, “is the cornerstone of what we do.” Her division will also “continue to charge violations of the securities laws for misconduct that clearly undermines market integrity, including accounting fraud, insider trading, wash trading, and market manipulation schemes.”

Ryan also added observations about the other requirements of the federal securities laws including public company reporting requirements. Violation of these requirements may not be “on par” with fraud, but there are circumstances, even where fraud is absent, where “compliance has failed in a way that poses risks to investors” or “risks to the integrity of the market,” that may “warrant enforcement.” At the same time, these circumstances may opportunity for the Enforcement Division, on the one hand, and those who might be subject to an enforcement action, on the other hand “to craft thoughtful resolutions in an appropriate case.”

Discussion

I am sure I was not alone in wondering, in the months following Ryan’s appointment, what she was doing in her new role, and how much of what the Enforcement Division was (and, more importantly, apparently was not) doing under the current administration reflected a conscious approach under her leadership. Prior to this speech, Ryan had not made any public remarks, which contributed to the speculation about her role and her approach to her position.

I have to say after reading her remarks, and also spending some time in connection with writing this post finding out more about her background and experience, that I feel reassured. From my perspective, her assertions in her speech all landed. Sure, a critical observer might note, she just said what she had to say. O.K., fine, but she said it.

I particularly give Ryan credit for expressly stating that “reports” that enforcement work has been “tossed to the wayside” as being “not only greatly exaggerated but flat out wrong.” While conceding that the under her the Division would be more focused on “quality and impact” rather than “chasing numbers,” she sought to warn that the Enforcement Division will not be supine. Would-be wrongdoers should be forewarned.

Ryan did give a nod to what may be her greatest challenge in backing up her words, which is that the agency staff, and in particular, the Enforcement Divisions staff, has been decimated by job reductions, staffing cuts, and hiring freezes. I have been told by knowledgeable people that the staff reductions are particularly challenging because in many cases the departed staff includes some of the most experienced personnel. Ryan did say, in a statement that could be interpreted as acknowledging this reality, that “I do not have unlimited resources at my disposal.” No, she does not.

Ryan’s words were unquestionably well-crafted. Her statements of principles and priorities are fine and fine-sounding. However, what may be even more interesting is what the Enforcement Division actually does in the weeks and months ahead, particularly given the impacts of the staffing reductions.

All of that said, however, I do have to say that I found Ryan’s remarks reassuring. As she tells it, the cop is still on the beat. Which is a good thing, for the sake of investors and of markets.