A September rise in U.S. securities cases left annual enforcement activity far below its recent pace, with The Brattle Group estimating that the SEC filed 308 actions in fiscal 2026.
That estimate is 148 lower than the 456 actions the SEC reported for fiscal 2025, a decline of about 32% calculated from the two figures. Brattle put its annual average for fiscal 2018 through 2025 at 710 actions, making the latest estimate 57% lower than that benchmark.
Filings increased as fiscal 2026 progressed. Brattle counted 93 actions in the first half and 215 in the second, including 99 in September. Five of the six second-half months exceeded their corresponding month in fiscal 2025, but none matched Brattle’s average for that month across fiscal 2018 through 2025.
The types of actions also varied. Securities offerings and delinquent filings each made up 21.4% of Brattle’s fiscal 2026 tally. Insider trading represented 12.3%, the largest share the firm has recorded since its series began in fiscal 2018.
The SEC has said it is focusing enforcement resources on misconduct that harms investors, including fraud and market manipulation. In its fiscal 2025 results, the agency argued that the number of actions alone does not establish how effective enforcement has been. It also said fraud cases can demand more time and resources.
Brattle Principal Jan Jindra cited a government shutdown, staffing levels and a change in enforcement leadership as context for the lower count. Brattle’s earlier report said the shutdown lasted from Oct. 1 to Nov. 12, 2025. The SEC said Enforcement Division Director Margaret A. Ryan resigned and Acting Director Sam Waldon took over on March 16.
Brattle Senior Associate Adrienna Huffman forecasts 350 to 450 actions in fiscal 2027. Even the top of that range would remain below Brattle’s fiscal 2018 through 2025 annual average. The next year’s filings will indicate whether September’s increase continues.
