In light of the Urban decision, the SEC has indicated it intends on expounding on its views of failure to supervise for legal and securities personnel.
Although several of the federal securities laws indicate the SEC has the authority to bring actions for failing to supervise or detect securities law violations, there has been no true definitive standard. The SEC counters that most of the cases brought clearly indicate such failure, and should serve as guides to professionals. However, the SEC does not appear ready to craft a universal standard.
Alas, with no real case on the horizon, legal and securities compliance personnel will continue to move about in the dark with no apparent direction from the SEC.