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SEC Enforcement Director Makes First Public Remarks on the Wells Process and Enforcement Priorities

By Miriam (Mimi) G. Bahcall, Tracy S. Combs, Richard M. Cutshall, William Mack & Daniel J. Wadley on February 13, 2026
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SEC Office

On Aug. 21, 2025, Judge Margaret Ryan, a former senior judge of the United States Court of Appeals for the Armed Forces, was named the Securities and Exchange Commission’s director of the Division of Enforcement. Some former Enforcement Division directors have made public statements shortly after their appointment, laying out their expected approach to federal securities law enforcement, to interactions with the defense bar, and their expected areas of priority for the Division during their tenure. Judge Ryan did not—until Feb. 11, 2026, when she made her first public remarks at the Los Angeles County Bar Association’s 56th Annual Securities Regulation Seminar, in a speech that focused on “principles, process, and priorities.”

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Photo of Miriam (Mimi) G. Bahcall Miriam (Mimi) G. Bahcall

Miriam G. Bahcall focuses her practice on a variety of financial services industry litigation and regulatory matters, as well as general commercial litigation. She has represented underwriters, broker-dealers, insurance companies, directors and officers in class action and derivative litigation. In addition, Mimi has…

Miriam G. Bahcall focuses her practice on a variety of financial services industry litigation and regulatory matters, as well as general commercial litigation. She has represented underwriters, broker-dealers, insurance companies, directors and officers in class action and derivative litigation. In addition, Mimi has represented broker-dealers, investment banks, investment management firms, and public issuers and their management and employees in investigations and disciplinary proceedings initiated by the SEC, FINRA, CBOE and state regulators. She has also conducted internal investigations of publicly traded domestic and foreign companies whose operations are in the United States and China. Additionally, Mimi has represented brokerage firms and their management in various customer-initiated cases, and injunction and arbitration proceedings.

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Photo of Tracy S. Combs Tracy S. Combs

Tracy serves as Co-Managing Shareholder of the Salt Lake City office. A former Regional Director at the U.S. Securities and Exchange Commission, she represents corporations, financial institutions, and individuals in a wide range of federal and state government investigations, litigation, and regulatory inquiries…

Tracy serves as Co-Managing Shareholder of the Salt Lake City office. A former Regional Director at the U.S. Securities and Exchange Commission, she represents corporations, financial institutions, and individuals in a wide range of federal and state government investigations, litigation, and regulatory inquiries nationwide, including those involving the SEC, the Department of Justice, and state Attorneys General. She also counsels clients in complex business disputes, tort litigation, and cybersecurity matters. As Utah Business Journal’s Legal Elite edition stated in 2025, Tracy can “navigate a wide range of legal situations and…easily handle a crisis for any client.”

Tracy joined GT after an eight-year tenure at the SEC, where she served in a variety of roles in San Francisco and Salt Lake City. Most recently, Tracy served as Director of the SEC’s Salt Lake Regional Office, where she oversaw some of its most high-profile cases. As a former SEC trial and investigative attorney in San Francisco, Tracy brought several groundbreaking enforcement actions, including the SEC’s first public company cybersecurity disclosure case and its first “shadow” insider trading case. Tracy served for three years in the Division of Enforcement’s former Cyber Unit, where she co-led its Cybersecurity & Regulated Entities group. In 2021 to 2022, Tracy served as counsel to the Director of Enforcement, advising on priority matters and coordinating with the SEC’s criminal and civil law enforcement partners nationwide.

Prior to her government service, Tracy was a litigator at a large law firm in Philadelphia and New York, with a focus on high-stakes white collar criminal matters, securities class actions, and complex commercial disputes, and clerked for the Honorable Luis Felipe Restrepo in the U.S. District Court for the Eastern District of Pennsylvania.

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Photo of Richard M. Cutshall Richard M. Cutshall

Richard M. Cutshall is Co-Chair of the firm’s Financial, Regulatory and Compliance Practice, Co-Chair of the firm’s Private Funds Group, and Co-Chair of the firm’s Investment Management Group. Rich has experience representing clients in a variety of investment management, general securities, and corporate

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Richard M. Cutshall is Co-Chair of the firm’s Financial, Regulatory and Compliance Practice, Co-Chair of the firm’s Private Funds Group, and Co-Chair of the firm’s Investment Management Group. Rich has experience representing clients in a variety of investment management, general securities, and corporate matters, including the representation of mutual funds, ETFs, and other funds registered under the Investment Company Act of 1940; fund and ETF independent directors; unregistered investment funds; federally registered, state registered, and federally and state exempt investment advisers; broker-dealers; and an array of public and private companies.

Rich represents investment adviser clients at all stages of their life cycle, from concept and formation through registration, daily operation through wind-down and exiting the business, including representing investment adviser clients on both the buy-side and sell-side in M&A transactions. He also represents clients in all aspects of investment company practice, including organizing and forming new funds and ETFs, registering mutual funds and ETFs with the SEC, and the acquisition and merger of public funds.

In the course of representing investment advisers and public and private funds, Rich advises Greenberg Traurig’s clients on all aspects of securities regulatory compliance, particularly including new and existing SEC rules; SEC examination, regulatory, and investigative initiatives and sweeps; the SEC’s proposal, adoption, and implementation of new regulations, such as the recently rewritten investment adviser marketing rule; and finding compliance solutions related to the regulatory scheme applicable to investment advisers and investment funds, including implementing both novel and long-standing SEC regulatory guidance and interpretations. He also advises clients on the day-to-day aspects of corporate governance, board and adviser fiduciary responsibility, and SEC compliance, as well as assisting clients in all aspects of SEC and other regulatory examinations.

Rich has given presentations on and assists a variety of investment management clients with their compliance with anti-money laundering laws, and has performed annual independent third party audits of several clients’ anti-money laundering policies, programs and controls.

Rich also has experience representing clients in many industries in the sale or acquisition of businesses, formation of corporate entities, sophisticated contract negotiations, and in obtaining, renewing and renegotiating the terms of financing business operations. He routinely works with clients’ chief executive officers, chief financial officers, directors, and in-house general and assistant general counsels, including occasionally working from clients’ corporate headquarters upon request. Rich works with corporate and finance clients of all sizes, from startup family-run businesses and entrepreneurial endeavors to Fortune 500 clients. He also has experience representing clients across many industries, including health care, data management, retail product display and advertising design and manufacturing, industrial manufacturing, and real estate management and brokerage industries.

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Photo of William Mack William Mack

William B. Mack is a co-chair of the Financial Regulatory & Compliance Practice. He is experienced in advising companies on regulatory and compliance matters relating to the Securities and Exchange Commission regulations, the Exchange Act, Anti-Money Laundering laws and Financial Industry Regulatory Authority

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William B. Mack is a co-chair of the Financial Regulatory & Compliance Practice. He is experienced in advising companies on regulatory and compliance matters relating to the Securities and Exchange Commission regulations, the Exchange Act, Anti-Money Laundering laws and Financial Industry Regulatory Authority (FINRA) rules.

William’s practice involves all aspects of broker-dealer regulation, including Self-Regulatory Organization (SRO) membership, supervision, employment, research, soft dollar arrangements, chaperoning of foreign broker-dealers, social media, use of foreign finders, anti-money laundering rules, alternative trading systems (ATS), exchanges, and market making issues. He also provides regulatory guidance to investment banking clients in connection with securities offerings and related trading issues.

William advises firms in the FINRA new membership (NMA) and the continuing membership (CMA) processes. William assists firms to develop or amend their written supervisory procedures and compliance manuals.

William routinely represents clients who are negotiating placement agent agreements, foreign finders agreements, clearing agreements, agreements with registered representatives and expense-sharing agreements.

William assists broker-dealers and their associated persons to respond to regulatory examinations and inquiries and provides effective representation in a range of enforcement proceedings with the SEC, FINRA, NYSE, state and foreign regulatory authorities. He regularly prepares and defends witnesses in FINRA on-the-record interviews and SEC testimony. Enforcement matters have involved issues including market manipulation, supervision, customer defalcations, insider trading, anti-money laundering, distribution of unregistered securities, direct market access, market making, soft dollar arrangements, cross border trading, electronic intrusion and customer impersonation, sales practices, supervision, private placements, ETFs, indexes, and other securities products.

William regularly addresses questions with respect to what activities require or are exempt from broker-dealer registration. William assists firms in obtaining guidance, interpretive letters, and no-action relief from FINRA and the SEC with respect to novel securities issues and the creation of new products and services. William also advises clients on cryptocurrency, tokenization, NFTs, DeFi structures, and digital asset exchanges and trading.

Prior to joining the firm, William was a Principal Counsel for Enforcement at FINRA. Before FINRA, he was the Director of the Executive Secretariat in the Office of the U.S. Trade Representative. William also served as a Deputy Associate Counsel at the White House, advising primarily on appointments and investigations. Before the White House, he practiced at large firms in New York. William clerked for Judge Robert L. Carter in the Southern District of New York.

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Photo of Daniel J. Wadley Daniel J. Wadley

Daniel Wadley is an experienced trial attorney with over 20 years of litigation experience, including an 11-year tenure at the SEC. His practice focuses on complex commercial litigation; securities litigation; SEC regulatory compliance, investigations, and enforcement actions; auditor liability; financial services regulation and

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Daniel Wadley is an experienced trial attorney with over 20 years of litigation experience, including an 11-year tenure at the SEC. His practice focuses on complex commercial litigation; securities litigation; SEC regulatory compliance, investigations, and enforcement actions; auditor liability; financial services regulation and compliance; white collar defense; and corporate internal investigations.

Daniel possesses deep institutional knowledge of SEC policies, practices and procedures. Prior to joining GT, Daniel served as the Director of the SEC’s Salt Lake Regional Office where he oversaw and managed all of the office’s investigations, its federal court litigation, and its administrative proceedings. He was a member of the SEC’s FCPA unit and oversaw multiple investigations into FCPA violations. Before taking on the role of Regional Director, Daniel was trial counsel in the Division of Enforcement and also senior counsel to the Directors of Enforcement in Washington, D.C. In his trial counsel role, Daniel represented the SEC in securities enforcement matters filed throughout the United States in both federal district courts and in SEC administrative actions. As senior counsel to the Directors of Enforcement, Daniel helped shape and oversee Agency enforcement priorities and policy, reviewing all recommended actions and settlements pending before the Commission.

Daniel has led litigation teams in federal and state court actions throughout the country. His experience ranges from complex commercial litigation disputes to highly technical SEC regulatory compliance. He has represented the largest accounting firms in the world, as well as individuals, banks and financial institutions, insurance companies, real estate developers, and public and private companies both large and small. He has unique experience in matters involving regulatory filings; digital currencies; financial statement and accounting fraud; corporate mismanagement and internal controls violations; internal investigations; Foreign Corrupt Practice Act violations; insider trading; Ponzi scheme and offering frauds; and broker-dealer and Investment Adviser fraud.

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  • Posted in:
    Banking, Finance and Securities
  • Blog:
    Financial Services Observer
  • Organization:
    Greenberg Traurig, LLP
  • Article: View Original Source

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