On February 24, 2026, the SEC announced changes to its Enforcement Manual (Manual), which constitute the first revisions since 2017. In theory, the modifications aim to ensure a “uniform Wells process,” giving respondents four weeks to prepare written and/or audiovisual submissions in the hope of swaying staff in the SEC’s Division of Enforcement (Division) not to pursue charges, to streamline protocols as to consideration of settlement recommendations and to overhaul the framework for evaluating cooperation by respondents in SEC enforcement matters. Although the updates to the Manual may be welcomed by many fund managers facing potential scrutiny from Division staff, their potential impact is likely to be limited. “Some of the updates may give a little bit more transparency to the Division’s internal process, but they should not really cause a fund manager to change how it does business,” summarized Fried Frank partner C. Dabney O’Riordan, the former chief of the Division’s Asset Management Unit. This article summarizes the material changes to the Manual and presents practical takeaways for fund managers based on insights shared by several legal experts. See “SEC Signals Continued Willingness to Pursue Technical Violations With No Apparent Investor Harm” (Oct. 16, 2025); and “Present and Former SEC Officials Discuss Strategy, Testimony, Proffers and Negotiations” (Apr. 17, 2025).