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- Professionals
- Gerald Hodgkins
A former Associate Director for the U.S. Securities and Exchange Commission’s Enforcement Division (SEC), Gerald “Jerry” Hodgkins has a broad regulatory enforcement practice focused on representing financial institutions, public companies, audit firms and individuals in investigations and enforcement actions brought by the key financial regulators. Mr. Hodgkins has extensive experience in matters pertaining to the SEC and in matters involving broker-dealer and investment adviser regulation, public company accounting and U.S. anti-corruption law. He also focuses on issues involving the Public Company Accounting Oversight Board (PCAOB) and the Financial Industry Regulatory Authority (FINRA).
During his 20-year tenure at the SEC, Mr. Hodgkins oversaw more than 100 enforcement matters, including high-profile cases involving, among other areas of the SEC’s jurisdiction, public company accounting and disclosure, the Foreign Corrupt Practices Act (FCPA), broker-dealer and investment adviser compliance, and insider trading. The enforcement actions he oversaw included the largest penalty in SEC history for issuer reporting and disclosure fraud and the first, and still largest, settlement involving Section 304 of the Sarbanes-Oxley Act of 2002.
Previous Experience
- U.S. Securities and Exchange Commission
- Associate Director (2010-2017)
- Assistant Director (2007-2010)
- Branch Chief (1999-2007)
- Staff Attorney (1997-1999)
October 8, 2019, Covington Alert
A pharmaceutical company, Mylan, N.V., recently paid $30 million to settle an SEC enforcement action alleging multiple disclosure failures arising from an investigation by the Department of Justice.
October 2, 2019, Covington Alert
The enforcement staff of the Public Company Accounting Oversight Board (“PCAOB”) recently issued guidance for when it will recommend to the PCAOB disclosing the identity of non-party audit clients in disciplinary orders against auditors. The guidance confirms a policy change that we identified earlier this year.
February 27, 2019, Covington Advisory
On February 26, 2019, the Public Company Accounting Oversight Board (“PCAOB”) for the first time issued disciplinary orders against auditors that protected the identity of the auditors’ client. In the past, the PCAOB had a practice of identifying the audit client by name in disciplinary orders if the matter involved violations of auditing standards by the ...
Q1 2019, Covington Alert
It was business as usual for FCPA enforcement in 2018. The U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) collected a total of $1 billion from seventeen corporate defendants, including through their share of two high-value, multi-jurisdictional enforcement actions. DOJ also announced thirteen new FCPA prosecutions ...
Winter 2019, Covington Alert
It was business as usual for FCPA enforcement in 2018. The U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) collected a total of $1 billion from seventeen corporate defendants, including through their share of two high-value, multi-jurisdictional enforcement actions. DOJ also announced thirteen new FCPA prosecutions ...
January 16, 2019, Covington Alert
On December 26, 2018, the U.S. Securities and Exchange Commission ("SEC") settled an enforcement action against Centrais Eléctricas Brasileiras S.A. ("Eletrobras"), an electric utilities holding company majority-owned and controlled by the Brazilian government.
Covington & Burling Partner Gerald Hodgkins on the SEC Proposal to Limit the Size of Whistleblower Awards
November 8, 2018, Corporate Crime Reporter
Gerald Hodgkins is featured in an interview with Corporate Crime Reporter regarding the SEC proposal to limit the size of whistleblower awards. Under current SEC rules, whistleblowers are entitled to an award of ten to thirty percent of the recovery. The securities industry is now pushing to limit the size of SEC whistleblower awards. Under a proposed SEC rule, ...
SEC Annual Report Indicates Shift in Enforcement Focus
November 6, 2018, Corporate Counsel
Gerald Hodgkins is quoted in Corporate Counsel regarding the SEC’s annual enforcement report. Reflecting on the data, Mr. Hodgkins says, “You’re seeing more cases that are really honed in on the operating metrics and financial goals of the company. These newer cases are focused on particular operating goals, operating metrics. It has increasing emphasis by the ...
November 3, 2018
Due to a flurry of enforcement activity in the last quarter of Fiscal Year 2018, which closed at the end of September, the Securities and Exchange Commission filed nearly 10% more cases in 2018 than in the year before. The agency topped last year's numbers in every major category of cases except issuer disclosure and accounting, which were down about 13% from ...
November 3, 2018, The New York Times
Gerald Hodgkins is quoted in The New York Times regarding SEC enforcement activity during the first 20 months of the current Administration. Mr. Hodgkins says there was an uptick in enforcement in 2018 against fraudulent stock offerings and investment advisers accused of lying and stealing. At the same time, the SEC brought fewer market manipulation cases, which ...
October 25, 2018, Covington Alert
On October 16, 2018, the Securities and Exchange Commission (the “Commission”) issued a Section 21(a) report of investigation (the “Report”) warning public companies about the importance of assessing the likelihood of cyber-related threats when designing internal accounting controls. The Report described the Division of Enforcement’s investigation of nine ...
October 5, 2018, Covington Alert
Over 3,000 commenters submitted letters to the Securities and Exchange Commission ("SEC") concerning the agency's recently proposed amendments to its whistleblower rules. This response reflects the perceived importance of the SEC's proposal to companies and employees.
July 19, 2018, Covington Alert
Last week, in SEC v. Cohen, a federal district court dismissed an SEC enforcement action, in its entirety, on statute-of-limitations grounds. Most notably, citing the Supreme Court’s 2017 Kokesh decision, the court held that the injunction sought by the SEC in the case "would function at least partly to punish Defendants and is therefore a penalty" for purposes ...
April 24, 2018, Covington Alert
On Wednesday, April 18th, the SEC introduced a much-anticipated package of proposed rules and formal guidance concerning the standards of conduct for financial professionals. The more than 1,000-page proposal, which emerged eight years after Congress required the agency to conduct a study on the topic, addresses whether investment advisers and broker-dealers ...
March 28, 2018, Commercial Dispute Resolution
Commercial Dispute Resolution highlights the arrival of David Luttinger and Gerald Hodgkins at Covington. Commenting on Luttinger's addition, Mitchell Dolin says that the firm was “drawn to his superb national reputation as a trial lawyer in the coverage field and to his strengths as an individual and colleague.” According to David Kornblau, Hodgkins’ “broad ...
SEC Settles Fourth Cherry-Picking Enforcement
March 13, 2018, Compliance Reporter
Gerald Hodgkins is quoted in a Compliance Reporter article regarding a recent settlement between Valor Capital Asset Management and the Securities and Exchange Commission. According to Hodgkins, the settlement serves as an example of the way the agency’s improved data analytics can help regulators spot potentially problematic activity. “What is different in this ...
February 23, 2018, Covington Alert
On Wednesday, the Supreme Court issued its much-anticipated decision in Digital Realty Trust, Inc. v. Somers. Ruling 9-0, the Court held that the Dodd-Frank Act prohibits retaliation against whistleblowers only if they reported suspected wrongdoing directly to the SEC.
Former SEC official joins Covington
February 21, 2018, Compliance Reporter
Gerald Hodgkins is quoted in a Compliance Reporter article regarding his recent arrival as a partner in Covington's Securities Litigation and Enforcement and White Collar Defense and Investigations practices. “I bring to the table a deep understanding of what the issues are that drive the SEC and division of enforcement, along with what pressures affect them and ...
Covington hires 20-year SEC veteran
February 13, 2018, Global Investigations Review
Gerald Hodgkins is quoted in a Global Investigations Review article regarding his recent arrival at Covington. According to Hodgkins, he chose Covington after witnessing its excellent defence work while at the U.S. Securities and Exchange Commission.
February 12, 2018
WASHINGTON—Gerald Hodgkins has joined Covington as a partner in the Securities Litigation and Enforcement and White Collar Defense and Investigations practices in Washington. Mr. Hodgkins most recently served as an Associate Director in the Enforcement Division of the Securities and Exchange Commission and has worked at the SEC’s Enforcement Division since ...
Former SEC Enforcer Joins Covington's DC Office
February 12, 2018, Law360
Gerald Hodgkins and David Kornblau are quoted in a Law360 article regarding Hodgkin's recent arrival as a partner in Covington's Securities Litigation and Enforcement and White Collar Defense and Investigations practices. Hodgkins says he is looking forward to “enhancing” Covington’s SEC enforcement practice, as well as complementing its white collar and ...
SEC Enforcer Hodgkins Lands at Covington & Burling
February 12, 2018, The National Law Journal
Gerald Hodgkins is quoted by The National Law Journal in an article regarding his recent move to Covington. "I was attracted to Covington because of the quality of its lawyers and its culture of teamwork and collaboration,” Hodgkins says. “I look forward to playing a key role in enhancing the firm’s SEC enforcement practice and complementing the firm’s prominent ...