The Securities Enforcement Empirical Database (SEED) tracks and records information for SEC enforcement actions filed against public companies traded on major U.S. exchanges and their subsidiaries.

Created by the NYU Pollack Center for Law & Business in cooperation with Cornerstone Research, SEED facilitates the analysis and reporting of SEC enforcement actions through regular updates of new filings and settlement information for ongoing enforcement actions. The variables tracked include defendant names and types, violations, venues, and resolutions.

Our goal is to shed light on the SEC’s securities law enforcement decisions.  SEED is the first public database to provide easily searchable and verified data to researchers, counsel, and corporations, as well as regular reports on developments and trends.
-- Professor Stephen Choi, Director of the Pollack Center for Law & Business.

The figure illustrates the number of SEC actions against public companies and subsidiaries in each fiscal year 2010 to 2019

See color accessible chart. See full text description.

SEC Enforcement Activity: Public Companies and Subsidiaries (November 2019)

Key takeaways from the SEED research report for FY 2019 include:

  • The SEC initiated a total of 526 independent actions in FY 2019, the highest number since FY 2016.  Of this total, 95 (18 percent) comprised new actions against public companies and subsidiaries, the most in any fiscal year tracked by SEED.
  • For the first time in the fiscal years covered by SEED, Investment Adviser/Investment Company was the most common allegation type in FY 2019 (35 actions), accounting for 37 percent of the total.
  • In 1H FY 2019, 100 percent of actions were filed as administrative proceedings. In 2H FY 2019, this dropped to 84 percent.
  • In FY 2019, actions with public company and subsidiary defendants in the Finance, Insurance, and Real Estate industry accounted for 58 percent of all actions, higher than the average of 48 percent over the prior nine fiscal years.
  • In FY 2019, the SEC noted cooperation by 76 percent of defendants, a record-high percentage.  The FY 2010–FY 2018 average was 51 percent.
  • Share Class Selection Disclosure Initiative (Share Class Initiative) actions accounted for 29 percent of the total actions with monetary settlements in FY 2019. These actions had an average monetary settlement of $3 million, substantially lower than the average of $21 million for all other actions.
  • Disgorgement and prejudgment interest comprised 59 percent ($852 million) of the $1.5 billion in monetary settlements imposed on public companies and subsidiaries in FY 2019, higher than the average of 51 percent from FY 2010 to FY 2018.

Prior SEED and Cornerstone Research Reports 

This project is a collaboration between these organizations:

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