Marking the first comprehensive update in eight years, the SEC’s Division of Enforcement (the Division) released a revised edition of its Enforcement Manual (the 2026 Manual). SEC Chairman Paul Atkins called the update a “long-overdue step,” and Division Director Margaret Ryan said the changes are intended to “ensure greater uniformity” and “reflect the Division’s best practices.” Although the 2026 Manual has many changes from the previous version, some will have a greater impact. In this article, we highlight the most significant revisions and discuss their practical implications.

Even though five years have passed since Congress enacted the Paycheck Protection Program (PPP) as an emergency response to the COVID‑19 pandemic, enforcement activity relating to PPP loans remains an active component of the federal government’s civil fraud agenda and—with the statute of limitations not expiring for another roughly five years—all indications are that it will continue to be an enforcement priority for the foreseeable future.