Subject to Inquiry: White Collar, Congressional, SEC, Energy Enforcement & Other Government Inquiries

You need to follow along closely because this can get a bit confusing.  As we all recall, in 2003, judgments were entered against 12 of the largest Wall Street firms that issued research and engaged in investment banking, commonly referred to as "The Global Settlement."  The Global Settlement imposed signficant restrictions on interactions between the research analysts and investment bankers at these firms in order to stymie the bankers from influencing analyst coverage decisions. 

The Global Settlement provided that with respect to any provision that had not been expressly superseded by subsequent rulemaking within five years, it was the expectation of the parties that, "the SEC would agree to an amendment or modification of such term, subject to Court approval, unless the SEC believes such amendment or modification would not be in the public interest."

Ultimately, the parties agreed to seek Court approval to modify specific provisions, rather than all, of the Global Settlement.  In an order issued March 15, 2010 (pdf), U.S. District Judge William H. Pauley III approved all of the parties proposed modifications, with the exception of one.

WSJ reported on March 17, 2010