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. It should be written with a clear theory of why charges are wrong on the facts, the law, or the public interest, and it should be paced to the staff's timeline, not the client's.

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

Anonymity is not absolute. There are circumstances — including award claims and certain enforcement contexts — in which identity may need to be confirmed.

The legal obligations attached to a private securities offering are determined by the nature of the offering — the type of investor solicited, the exemption relied on, the manner of solicitation — not by the dollar amount raised. Many founders are surprised to learn that a small raise can carry the same disclosure obligations as a much larger one.

Whether a PPM is technically required and whether one should be prepared are separate questions. Both are worth answering deliberately.

Initial conversations are brief and confidential, subject to a conflict check. The firm declines engagements that fall outside its core competencies, and refers them out when a sensible referral exists.

Because the firm is solo by design, the attorney on the call is the attorney on the matter. There is no associate layer to which the work will be handed.

Christina Milnor is admitted in Virginia and the District of Columbia. Federal regulatory matters, including SEC and SRO proceedings, are handled nationally, subject to pro hac vice admission or local counsel arrangements where required.