SEC v. Bear, Stearns & Co. Inc.; J.P. Morgan Securities Inc.; Lehman Brothers, Inc.; Merrill Lynch, Pierce, Fenner & Smith Incorporated; U.S. Bancorp Piper Jaffray, Inc.; UBS Securities LLC, et al., No. LR-26434, Southern District of New York (Dec. 5, 2025) — Press Release
raw: Global Research Analyst Settlement
Global Research Analyst Settlement, No. LR-26434 (S.D.N.Y. Dec. 5, 2025)
summary
The SEC has consented to terminate remaining undertakings in the Global Research Analyst Settlement following the implementation of FINRA Rule 2241 to address research conflicts.
paragraph
The SEC consented to modify final judgments from 2003 and 2004 involving twelve investment banks and two individuals. These original enforcement actions addressed conflicts of interest between equity research analysts and investment banking personnel. The modification follows the 2015 adoption of FINRA Rule 2241, which now supersedes the previous settlement undertakings.
narrative
The SEC has consented to the termination of remaining undertakings in the Global Research Analyst Settlement, which originally involved twelve investment banks and two individuals. The settlement addressed conflicts of interest between equity research analysts and investment banking personnel. Following the 2015 adoption of FINRA Rule 2241, which provides the regulatory framework for these conflicts, settling firms moved to terminate their remaining obligations. The SEC acknowledged the sunset provision in the original judgments and agreed that modification is in the public interest. Major firms involved include Bear Stearns, J.P. Morgan, Goldman Sachs, and Morgan Stanley. The final modification remains subject to court approval.
Classified investment-adviser-fraud(confidence 90%). EDGAR detection: forms ADV/ADV-E/ADV-W/Form D· recall 33% / precision 13%. detection rule →
Parties
Securities and Exchange CommissionBear, Stearns & Co. Inc.J.P. Morgan Securities Inc.Lehman Brothers, Inc.Merrill Lynch, Pierce, Fenner & Smith IncorporatedU.S. Bancorp Piper Jaffray, Inc.UBS Securities LLCGoldman, Sachs & Co.Citigroup Global Markets Inc.Credit Suisse First Boston LLCMorgan Stanley & Co. IncorporatedDeutsche Bank Securities Inc.Thomas Weisel Partners LLC
Keywords
seccivresearchincglobal researchresearch analystfinal judgmentsamendment modificationglobalanalyst settlementsubject approvalresearch analystsmodification publicpublic interestsecurities
Extracted insights
Entities 2
- agency Securities and Exchange Commission
- person settling firms
Triples 7
- Securities And Exchange Commission consented to modifications to the October 2003 and September 2004 final judgments against settling firms still covered by the Global Research Analyst Settlement
- Securities And Exchange Commission approved Rule 2241 (Research Analysts and Research Reports) adopted and implemented by FINRA in 2015
- Settling firms filed motions to terminate the remaining undertakings in the Addendum based on the adoption and implementation of FINRA Rule 2241
- Securities And Exchange Commission acknowledges the sunset provision in Addendum a of the final judgments and the passage of FINRA Rule 2241
- Securities And Exchange Commission believes modification of the Judgment is in the public interest
- Court approved modifications to the final judgments subject to court approval
- Court modified the Addendum by court order in March 2010 to remove or modify certain provisions
Extracted body text (2,965c)
U.S. SECURITIES AND EXCHANGE COMMISSIONLitigation Release No. 26434 / December 5, 2025SEC v. Bear, Stearns & Co. Inc., No. 03 Civ. 2937 (S.D.N.Y.)SEC v. J.P. Morgan Securities Inc., No. 03 Civ. 2939 (S.D.N.Y.)SEC v. Lehman Brothers, Inc., No. 03 Civ. 2940 (S.D.N.Y.)SEC v. Merrill Lynch, Pierce, Fenner & Smith Incorporated, No. 03 Civ. 2941 (S.D.N.Y.)SEC v. U.S. Bancorp Piper Jaffray, Inc., No. 03 Civ. 2942 (S.D.N.Y.)SEC v. UBS Securities LLC, f/k/a UBS Warburg LLC, No. 03 Civ. 2943 (S.D.N.Y.)SEC v. Goldman, Sachs & Co., No. 03 Civ. 2944 (S.D.N.Y.)SEC v. Citigroup Global Markets Inc., f/k/a Salomon Smith Barney Inc., No. 03 Civ. 2945 (S.D.N.Y.)SEC v. Credit Suisse First Boston LLC, f/k/a Credit Suisse First Boston Corp., No. 03 Civ. 2946 (S.D.N.Y.)SEC v. Morgan Stanley & Co. Incorporated, No. 03 Civ. 2948 (S.D.N.Y.)SEC v. Deutsche Bank Securities Inc., No. 04 Civ. 6909 (S.D.N.Y.)SEC v. Thomas Weisel Partners LLC, No. 04 Civ. 6910 (S.D.N.Y.)SEC Consents to Termination of Undertakings in Global Research Analyst SettlementThe Securities and Exchange Commission today consented to modifications to the October 2003 and September 2004 final judgments against settling firms still covered by the Global Research Analyst Settlement, a global settlement of SEC and other enforcement actions against twelve investment banks and two individuals. The modifications are subject to court approval.The final judgments contained an Addendum with undertakings that addressed potential conflicts of interest between equity research analysts and investment banking personnel. The Addendum also included a sunset provision for newly adopted rules that would supersede the undertakings, and stated that for terms that were not superseded, the SEC would agree to an amendment or modification, subject to court approval, unless the SEC believed the amendment or modification would not be in the public interest. The Addendum was modified by court order in March 2010 to remove or modify certain provisions. The revised Addendum also stated that the SEC would agree to further amendment or modification of the undertakings, subject to court approval, unless the SEC believed the amendment or modification would not be in the public interest.In 2015, FINRA adopted and implemented, and the SEC approved, Rule 2241 (Research Analysts and Research Reports), which addresses conflicts of interest between research analysts and investment banking personnel within registered broker-dealers.The settling firms filed motions in June and December 2025 seeking to terminate the remaining undertakings in the Addendum based in part on the adoption and implementation of FINRA Rule 2241. In its responses to the motions, the SEC acknowledges the sunset provision in Addendum A of the final judgments and the passage of FINRA Rule 2241, states that it “believes modification of the Judgment is in the public interest,” and consents to the requested modification of the final judgments.
OCR text (2,965c · html-text · 99% conf)
U.S. SECURITIES AND EXCHANGE COMMISSIONLitigation Release No. 26434 / December 5, 2025SEC v. Bear, Stearns & Co. Inc., No. 03 Civ. 2937 (S.D.N.Y.)SEC v. J.P. Morgan Securities Inc., No. 03 Civ. 2939 (S.D.N.Y.)SEC v. Lehman Brothers, Inc., No. 03 Civ. 2940 (S.D.N.Y.)SEC v. Merrill Lynch, Pierce, Fenner & Smith Incorporated, No. 03 Civ. 2941 (S.D.N.Y.)SEC v. U.S. Bancorp Piper Jaffray, Inc., No. 03 Civ. 2942 (S.D.N.Y.)SEC v. UBS Securities LLC, f/k/a UBS Warburg LLC, No. 03 Civ. 2943 (S.D.N.Y.)SEC v. Goldman, Sachs & Co., No. 03 Civ. 2944 (S.D.N.Y.)SEC v. Citigroup Global Markets Inc., f/k/a Salomon Smith Barney Inc., No. 03 Civ. 2945 (S.D.N.Y.)SEC v. Credit Suisse First Boston LLC, f/k/a Credit Suisse First Boston Corp., No. 03 Civ. 2946 (S.D.N.Y.)SEC v. Morgan Stanley & Co. Incorporated, No. 03 Civ. 2948 (S.D.N.Y.)SEC v. Deutsche Bank Securities Inc., No. 04 Civ. 6909 (S.D.N.Y.)SEC v. Thomas Weisel Partners LLC, No. 04 Civ. 6910 (S.D.N.Y.)SEC Consents to Termination of Undertakings in Global Research Analyst SettlementThe Securities and Exchange Commission today consented to modifications to the October 2003 and September 2004 final judgments against settling firms still covered by the Global Research Analyst Settlement, a global settlement of SEC and other enforcement actions against twelve investment banks and two individuals. The modifications are subject to court approval.The final judgments contained an Addendum with undertakings that addressed potential conflicts of interest between equity research analysts and investment banking personnel. The Addendum also included a sunset provision for newly adopted rules that would supersede the undertakings, and stated that for terms that were not superseded, the SEC would agree to an amendment or modification, subject to court approval, unless the SEC believed the amendment or modification would not be in the public interest. The Addendum was modified by court order in March 2010 to remove or modify certain provisions. The revised Addendum also stated that the SEC would agree to further amendment or modification of the undertakings, subject to court approval, unless the SEC believed the amendment or modification would not be in the public interest.In 2015, FINRA adopted and implemented, and the SEC approved, Rule 2241 (Research Analysts and Research Reports), which addresses conflicts of interest between research analysts and investment banking personnel within registered broker-dealers.The settling firms filed motions in June and December 2025 seeking to terminate the remaining undertakings in the Addendum based in part on the adoption and implementation of FINRA Rule 2241. In its responses to the motions, the SEC acknowledges the sunset provision in Addendum A of the final judgments and the passage of FINRA Rule 2241, states that it “believes modification of the Judgment is in the public interest,” and consents to the requested modification of the final judgments.