The SEC has been focusing on traditional areas such as insider trading, the FCPA, financial fraud and regulated entities in its enforcement activities. At the same time, it is moving forward with new tools and new authority from Dodd-Frank. In some key areas the agency appears to be essentially rewriting the rules through enforcement actions. At the same time, questions are being raised about the effectiveness of the so-called rejuvenation of the enforcement program. In this essential program for anyone dealing with the SEC, Tom Gorman of Dorsey & Whitney LLP projects the direction of SEC enforcement and analyzes the key questions about it.