Straight talk and candid answers.

A Wells notice is a letter from SEC enforcement staff advising a person that the staff intends to recommend that the Commission authorize an enforcement action. It is not a charge. It is an opportunity to respond, a Wells submission, before the Commission votes on whether to authorize a case.

The submission is the single highest-leverage moment in an SEC investigation for the targets of investigation. It should be written with the Commissioner audience in mind, not only the SEC staff audience.

Yes. Under Rule 21F of the Securities Exchange Act, an individual may submit a Form TCR anonymously, provided the submission is made through an attorney. Counsel verifies the whistleblower's identity to the Commission at the time any award is claimed.

Anonymity vis-à-vis the staff, and others, is not absolute. There are circumstances, including award claims and certain enforcement scenarios, where identity may need to be disclosed.

Not necessarily. For a private securities offering, the need for a private placement memorandum depends less on the size of the raise and more on the structure of the offering, including the investors involved, the exemption relied on, and how the securities are being offered.

Whether a PPM is technically required and whether one should be prepared are separate questions. Both are worth understanding, and answering, before the raise.

Initial conversations are brief and confidential, subject to a conflict check. The firm declines engagements that fall outside its core areas of practice.

Because the firm is solo by design, the attorney on the call is the attorney on the matter. There is no handoff.

Christina Milnor is admitted in Virginia and the District of Columbia. Because SEC and FINRA proceedings are not state-court litigation, her practice in them is national.