Kit Addleman in Compliance Week: "Broken Windows" Strategy Raises Risk-Management Fears


Mary Jo White, chairman of the Securities and Exchange Commission, first dropped the phrase “broken windows” on the compliance world during a speech in October 2013.

Just as police officers deter serious crime by tackling small quality of life issues—from graffiti to turnstile jumpers to, yes, breaking windows—White’s idea was to do the same with SEC rules and requirements. “It is important to pursue even the smallest infractions,” she said …

Count Kit Addleman, a partner with the law firm Haynes and Boone and former regional director of the SEC’s Atlanta office, among those who don’t believe the Commission will have much trouble balancing small infractions with larger concerns. The crackdown on late filings in November was handled by just one staffer and an assistant director at the New York regional office, she notes.

“It doesn’t take a lot to bring these cases,” Addleman says. “They are not taking testimony and don’t need to do a full-fledged investigation in the way they would have to for larger accounting fraud or a Foreign Corrupt Practices Act violation.”

Excerpted from Compliance Week. To read the full article, click here.

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