Going Public By Norm Champ: A Tell-Some Exposé Of 'Bureaucratic Warfare,'' 'Bizarro Decisions' And 'Political Hit Jobs,' By A Former Director Of The SEC's Division Of Investment Management

Norm Champ, on his first day as director of the Securities and Exchange Commission's (SEC) Division of Investment Management (Division) in Washington, DC, couldn't get into his office. He found the door locked, and no one in the Division had a key. After security personnel finally let him in, he couldn't log onto his computer. It took him more than an hour to have assistants get him online. He assesses these mishaps as "portents of the larger breakdowns in accountability I would soon encounter."

Champ, in his recount of a five-year sojourn with the federal agency (McGraw-Hill Education), reveals these and other obstacles he encountered trying to achieve the SEC's mission, the tactics he summoned to overcome as many as he could, the hard-won successes he celebrates, and the "dragons remained to be slain."

Other former directors, notably Joel Goldberg, Barry Barbash, Paul Roye, and Buddy Donohue, to their credit, have freely recounted—and even critiqued—their adventures as division directors. But they have done so largely in speaking at legal conferences and bar association meetings. Champ is the first to write a book.

Make no mistake, there is much in the book about the positives of the SEC and its Staff and their dedicated pursuit of the agency's three-part mission: protecting investors, ensuring fair and orderly markets, and facilitating capital formation. There is also a good bit in the book about the negatives that Champ discovered and sought to eliminate or at least neutralize.

The readership of this periodical consists mainly of practicing lawyers rather than probing historians. So, this review, at the risk of misrepresenting the book, focuses on what lawyers face in practicing before the SEC on an ongoing basis.

This is really two books in one. It's "Going Public" in the sense of Champ's making known inside SEC information. It's also "Going Public" in the personal sense of Champ's moving from the private to public sector.

Inside SEC Information

Champ's story covers the five-year period from January 2010 to January 2015, when he joined the SEC Staff as Associate Regional Director for Examinations in the SEC's New York Regional Office, became deputy director of the Office of Compliance Inspections and Examinations, and served two and a half years as Division director in the SEC's headquarters in DC.

He lays out, in no uncertain terms, his confrontation with what he figured to be "a chaotic and messy situation" and "anarchic dysfunction." He soon learned that "the SEC wasn't a typically dysfunctional bureaucracy that needed to fix what had been broken. Rather, there were parts of it that had never been built." He wryly notes that the Staff calls the Division "The Wax Museum," because "it's frozen in time and place."

Champ's difficulties at the SEC ranged from the macro to the micro.

As an example of the macro, some of the more intriguing commentary has to do with Champ's battle, as an SEC representative, to prevent the Financial Stability...

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