After the JPMorgan case, every SEC investigation of a registered firm presumes some off-channel communications exist. Given that investigative mentality, firms face enforcement challenges. At a recent Practising Law Institute panel, experts from Gibson Dunn, Morgan Lewis, Simpson Thacher, WilmerHale and King & Spalding discussed these challenges and other SEC regulatory trends, including potential implications of the agency's flurry of proposed rules and its cooperation standards during an examination. We distill their insights. See “Present and Former SEC Officials Discuss the Commission’s Latest Examination and Enforcement Tactics and Priorities” (Jun. 29, 2022).