January 07, 2014
The Door Will Revolve More Slowly For The SEC's Senior Litigators
Posted by David Zaring

I'm unworried about the revolving door (these guys are, if you want a different view), but one of the traditional ways to slow it has been to require cooling off periods before former government employees can represent clients before their former colleagues.  These periods get longer the higher up the food chain one goes; the SEC, however, has long received an exemption from them for its litigators, because it used the revolving door as an enticement for recruitment.

Times are tough for lawyers, however, and the SEC no longer has these recruting problems, and so requested that the exemption be removed.  Hey presto - it happened, in a rule that is being passed without going through notice and comment (which isn't really very kosher, especially if the intital exemption did go through notice and comment).

If anything, the most interesting aspect of this development was the basis for the exemption itself, which was so that the SEC could tell senior lawyers that they could supercharge their private sector earning potential if they took high-level enforcement jobs.  At this point, maybe everyone knows this, and cooling off periods haven't hurt the private sector earning potential of senior prosecutors at Justice any either.

But it also shows that a benefit, once given, can always be taken away.

Administrative Law, Securities | Bookmark

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