This week’s SEC filings paint a portrait of an agency in transition. From a historically thin enforcement docket to eye-popping executive pay packages and billion-dollar bitcoin bets, here are the filings that caught our attention.
SEC Reports Lowest Enforcement Activity in Two Decades
The Commission’s FY2025 enforcement results, released April 7, reveal just 456 total enforcement actions — the fewest in at least 20 years and a steep drop from FY2024’s 583. The headline recovery figure of $17.9 billion is misleading: roughly $14.9 billion of that traces to a single decades-old case against Robert Allen Stanford’s Ponzi scheme. Strip that out, and actual new recoveries fall well below recent norms. The Division acknowledged it is pivoting away from volume-driven enforcement toward fraud and market manipulation cases, which together now represent 33 percent of standalone actions, up from 26 percent the prior year. Staff departures — an 18 percent reduction attributed to DOGE-related initiatives — raise questions about the agency’s capacity to police emerging risks in private credit and AI-driven markets.
Gibson Dunn Partner Tapped as Enforcement Director
One day after the enforcement report, the SEC announced that David Woodcock, a Gibson Dunn & Crutcher partner in Dallas and former director of the SEC’s Fort Worth Regional Office (2011–2015), will lead the Division of Enforcement beginning May 4. He replaces Judge Margaret Ryan, who resigned after just six months following reported clashes with agency leadership over enforcement direction. Woodcock inherits a division of more than 1,000 staff and will be tasked with executing the Chairman’s narrower enforcement vision.
Wells Fargo Proxy Reveals ~$100 Million CEO Pay Package
Wells Fargo’s DEF 14A, filed March 18, discloses that CEO Charles Scharf received approximately $100 million in total compensation for 2025 — $40 million in approved pay plus a $60 million special equity award tied to what the Board called his leadership in driving the bank’s transformation, particularly following the lifting of the Federal Reserve’s asset cap. The Board eliminated pre-set total compensation targets in 2025, instead relying on what it described as a principles-based evaluation. This package may draw scrutiny from proxy advisory firms and institutional shareholders ahead of the April 28 annual meeting.
Strategy Inc. Discloses $14.5 Billion Unrealized Bitcoin Loss
Strategy Inc. (formerly MicroStrategy) filed an 8-K on April 6 disclosing that it acquired 4,871 bitcoin between April 1–5 for $329.9 million at an average cost of roughly $67,718. The company’s aggregate holdings now stand at 766,970 BTC purchased for $58.02 billion. Notably, Strategy also reported a $14.46 billion unrealized loss on digital assets for Q1 2026 — partially offset by a $2.42 billion deferred tax benefit. The firm continues to fund purchases through at-the-market stock sales, with $49.75 billion in remaining ATM capacity between its MSTR and STRC programs.
JANA Partners Files 13D on Alkami Technology
Activist fund JANA Partners disclosed a 5.1 percent stake in fintech company Alkami Technology (ALKT), purchasing 5.4 million shares valued at approximately $119 million. The Schedule 13D, filed April 1, states JANA believes the shares are undervalued. JANA-managed accounts also hold cash-settled swaps on an additional 2.95 million shares, representing 2.8 percent economic exposure. The filing may signal an activist campaign ahead, potentially including board representation or a push for strategic alternatives. Alkami provides digital banking solutions to credit unions and community banks.
Filings that may warrant deeper TIJ investigation: the Wells Fargo CEO compensation package and Strategy Inc.’s growing unrealized losses deserve follow-up analysis pieces examining governance and disclosure implications, respectively.