Criminal Defense Lawyers

Is an SEC Subpoena Serious?

The SEC investigation is civil. Except it isn’t. That subpoena in your hands – the one that says “Securities and Exchange Commission” at the top, the one your attorney told you is “just regulatory” – everything you say in response to it gets shared with Department of Justice prosecutors who can charge you criminally. You thought you were in civil proceedings. You’re actually building a criminal case against yourself. Most people who receive SEC subpoenas don’t realize this until they’re already indicted. By then, six months of “cooperative” statements to SEC attorneys have become evidence in a federal prosecution. Here’s the question nobody asks when that subpoena arrives: Is the DOJ already involved?

What an SEC Subpoena Actually Means

An SEC subpoena is not a fishing expedition. By the time that document arrives, the Securities and Exchange Commission has already found evidence of securities law violations. Think about that for a second. They don’t issue subpoenas because they’re curious. They issue them because they’ve already determined there are sufficient concerns to devote agency resources to a formal investigation. As of March 2025, launching a formal investigation requires Commission approval – that’s five commissioners voting that your situation warrants investigation. The subpoena is not the beginning of their inquiry. It’s confirmation that the inquiry already found something.

There are two types of SEC subpoenas. A subpoena ad testificandum compels you to provide testimony – either in your individual capacity or as a representative of a company. A subpoena duces tecum compels you to produce documents. Both types come with the same 30-day response deadline. Both types create the same document preservation obligations that extend indefinitely until the investigation concludes. And both types mean the same thing: you’re now part of a federal securities investigation that will take two to five years to resolve.

The question isnt whether an SEC subpoena is serious. The question is whether YOU are the target or just a witness. And heres the uncomfortable truth: even if the SEC tells you your “just a witness” – your subpoenaed to provide information about someone else, dont worry, your not under investigation – your testimony can reveal YOUR liability. One inconsistent statement. One document you forgot to mention. One transaction you didnt realize was problematic. The investigation just pivoted. You came to provide background about your colleague. You left as the subject of the inquiry.

The Timeline That Destroys People

You have 30 days to respond. The SEC has two to five years to investigate. Everyone focuses on that 30-day deadline – scrambling to gather documents, figure out whats privileged, decide wheather to cooperate or assert rights. But think about what your actualy doing in those 30 days. Your making permanent decisions. Once you produce documents, you cant un-produce them. Once you testify, you cant take it back. The transcript is locked. Every answer becomes sworn testimony that prosecutors can use for the next five years.

Meanwhile, the SEC works on geological time. Theyll take two years just to review what you produced. Another year to conduct follow-up testimony. Another year to determine wheather to bring charges. Your entire life is on hold – you cant change jobs in the securities industry, you cant get new certifications, you cant move forward with major business decisions because this investigation is hanging over everything. And heres the part that makes it worse: you had one month to make the decisions theyll spend half a decade analyzing. There not operating on your timeline. Your operating on theirs.

Miss that 30-day deadline by even one day and the SEC files an enforcement action in federal court to compel compliance. That enforcement filing is public. Anyone can read it. It details what they think you did, what there investigating, your role, what they want from you. So now the thing that was confidential – the subpoena, the investigation, your alleged involvement – just became a permanent public court record that shows up in Google searches of your name. You tried to buy more time. You created permanent public exposure.

The Civil Investigation That Isnt Civil

OK so the SEC has no criminal jurisdiction. They handle regulatory enforcement – fines, industry bars, cease-and-desist orders. No prison time. No criminal record. Just civil penalties. Except thats not how it actualy works. The SEC and Department of Justice have formal information-sharing agreements. Everything you say to SEC attorneys – every interview, every piece of testimony, every document you produce – gets shared with DOJ prosecutors. Those prosecutors can bring criminal charges for the same conduct the SEC is investigating civilly.

This is called parallel investigations and its standard practice, not the exception. Sometimes youll recieve subpoenas from both agencies within days or weeks of each other – thats confirmation that criminal and civil investigations are running simultaneously. Sometimes an SEC attorney will casually mention “the DOJ has taken an interest” in your case. Thats code. That means criminal prosecutors are already reading everything youve said to the SEC. That means your calculation about cooperation just changed completly.

Look, heres why this matters. People think “its just civil” means the worst outcome is paying a fine or loosing there securities license. So they cooperate fully with the SEC. They provide detailed testimony about there knowledge, there intent, what they beleived at the time – all the mens rea elements that criminal prosecutions require. There thinking “I need to show the SEC Im cooperative so theyll go easy on penalties.” What there actualy doing is providing prosecutors with evidence of criminal intent. The civil investigation was building the criminal case the whole time.

How to Tell If DOJ Is Already Involved

Most people dont realize the Department of Justice is investigating them until there charged. But there are signals that appear months earlier if you know what to look for. SEC attorneys use specific code phrases. “The DOJ has taken an interest in this matter” dosent mean there casually curious. It means criminal prosecutors have opened a parallel investigation and are activly coordinating with the SEC. “Were working with other agencies” is another tell – thats bureaucratic language for information sharing with criminal authorities.

The timing of subpoenas reveals parallel investigations too. If you recieve an SEC subpoena and a DOJ grand jury subpoena within the same month, thats not coincidence. Thats coordinated investigative strategy. If the SEC subpoena arrives first but asks for documents that only matter for criminal prosecution – evidence of intent, emails about what you beleived, records of conversations about your knowledge of specific transactions – thats the SEC gathering evidence for prosecutors.

The types of questions shift once DOJ is involved. Civil SEC investigations focus on what happened – the transactions, the timeline, who was involved, what documents exist. Questions about facts and conduct. But once criminal prosecutors are in the picture, the questions change. They want to know what you KNEW. What you BELIEVED. What your INTENT was. Those are mens rea questions – the mental state elements required for criminal convictions. If your SEC testimony suddenly includes extensive questioning about your knowledge and beliefs, criminal charges are being considered.

By the time you notice these signals, the parallel criminal investigation has usualy been running for three to six months. Everything you already told the SEC – thinking it was just a civil regulatory matter – is now part of a criminal case file. This is why expereinced securities defense attorneys ask about DOJ involvement immediatly, before any testimony or document production. Once youve cooperated with the SEC under the assumption its civil only, you cant walk that back when you learn prosecutors are involved.

What “Preserve Everything” Actualy Means

The subpoena includes language about preserving all potentially relevant documents. Sounds straightforward. Keep your files, dont delete anything, maintain records. But what that language actualy triggers is a litigation hold – a formal legal obligation that extends far beyond your own files and continues indefinatly until the investigation concludes years later.

A proper litigation hold means sending preservation notices to every employee who might have information related to the investigation. Not just the executives or the people named in the subpoena. Every assistant who scheduled meetings. Every analyst who worked on the transactions. Every person who might have sent or recieved an email about anything potentially relevant. Those employees must preserve everything – emails, texts, voicemails, Slack messages, Teams chats, handwritten notes, calendar entries, draft documents, metadata.

Your IT department has to suspend auto-delete policies. Most companies have emails that automaticaly delete after 90 days or backup tapes that get overwritten on rotation schedules. All of that stops the moment you recieve a subpoena. You need to preserve backup tapes indefinatly. Forensically image computers and phones of key personnel so theres a record of what existed at the time of the subpoena. Maintain voicemail systems that would normaly purge old messages. This costs enormous amounts of money and creates massive operational burdens, but failing to do it creates evidence of spoliation.

And heres the trap: the preservation obligation applies to documents you dont even know are relevant yet. Relevance gets determined later – sometimes years later when investigators finaly review materials and decide what they need. If an employee cleaned out there inbox six months into the investigation because they didnt realize an email thread was important, thats spoliation. Thats evidence destruction. Thats potential obstruction of justice charges under 18 U.S.C. § 1505, which carries up to five years in federal prison. Someone thought they were doing routine email maintenance. They just commited a federal crime.

The Cooperation Scoring System Nobody Explains

Look, every article about SEC investigations says “cooperation matters” like its generic advice. Be nice, work with investigators, things will go better. But the SEC dosent evaluate cooperation based on wheather you were pleasant in meetings. They have a quantified scoring system that directly determines penalty amounts and wheather you face industry bars that end your career.

In 2024, 75% of public-company defendants had there cooperation explicitly noted in settlement documents. Thats not happening because the SEC decided to be nice. Its happening because cooperation credit is built into the SEC Enforcement Manual as a structured framework. They calculate penalty reductions based on measureable factors: wheather you self-reported violations before the SEC discovered them, how quickly you cooperated once they initiated the investigation, and wheather your cooperation was complete or selective.

Self-reporting before the SEC finds evidence produces substantial penalty reductions. The enforcement manual dosent use vague language like “may be considered.” It explicitly states that self-reporting affects penalty calculations. Companies that discover securities violations internaly and report them before recieving subpoenas get quantified credit. The difference isnt subtle – its the difference between a $500,000 penalty and a $5 million penalty. Its the difference between a six-month industry suspension and a permanent bar from the securities industry.

Timing matters in ways people dont realize. Early cooperation throughout the investigation – providing documents promptly, making personnel available for testimony without delays, not forcing the SEC to subpoena every piece of information – that gets noted. Late cooperation after the SEC has already gathered most evidence through other means gets noted differently. Lack of cooperation gets specificaly cited in enforcement actions as an aggravating factor that increased penalties. This isnt goodwill. This is arithmetic. The SEC is calculating penalty amounts using cooperation as a measureable variable.

But heres were the civil/criminal paradox returns. Cooperation that reduces SEC civil penalties can provide evidence for DOJ criminal prosecution. Detailed testimony about what you knew, when you knew it, and what you intended – thats cooperation from the SECs civil perspective and confession from the DOJs criminal perspective. Once DOJ is involved, full cooperation with the SEC becomes dangerous. The cooperation scoring system that reduces fines can increase criminal exposure. This is why determining wheather parallel criminal investigation exists has to happen before you make cooperation decisions.

The Publicity Trap

Everyones instinct when recieving a subpoena is to fight it. Dont give them anything without a battle. Make them work for every document. Assert every possible privilege. Delay, negotiate, push back. Keep the investigation quiet. Protect your reputation. Except this strategy creates the exact outcome your trying to avoid.

SEC subpoenas are not self-enforcing. The SEC is a civil regulatory agency, not law enforcement. They cant show up with a warrant and seize your records. They cant arrest you for non-compliance. If you refuse to respond to there subpoena, they have to go to federal district court and file an enforcement action asking a judge to compel your compliance. That enforcement filing is a public court document. Anyone with internet access can read it.

These enforcement filings arent minimal procedural documents. They detail the nature of the investigation, your alleged role, the conduct under scrutiny, and what evidence the SEC wants from you. Everything that was confidential about the investigation – the fact that its happening, what its about, whos involved – becomes public information the moment the SEC files for enforcement. Court records show up in legal databases. Journalists monitor federal court filings for securities enforcement actions. Your name, your company, and the allegations all become searchable public information.

And heres what makes it permanent: FINRAs BrokerCheck system picks up enforcement actions immediatly. BrokerCheck is a public database were anyone can search your name and see your entire regulatory history. Potential employers check it. Clients check it. Compliance departments at every securities firm check it automaticaly during hiring. Once an SEC enforcement action appears on BrokerCheck, it stays there forever. Theres no expungement process. You cant seal the records. You cant get it removed even if the underlying investigation concludes with no findings. A single decision to refuse subpoena compliance creates a permanent public record that follows you for 30 or 40 years across your entire career.

So the calculation isnt “should I fight this subpoena?” The calculation is “can I afford to make this investigation public?” Because refusing compliance garentees publicity. The confidential subpoena becomes a public enforcement action. The quiet investigation becomes searchable court records. You tried to protect your privacy. You created a permanent public record instead.

Why “Im Just a Witness” Dosent Mean Your Safe

The SEC says they want to talk to you about someone else. Your not the target. There investigating your supervisor, your colleague, someone at the company, and they just need background information from you. Your a witness, not a subject. Dont worry, your not under investigation. People relax when they hear this. They think “Im just helping investigators understand what happened. This dosent involve me.”

Except witness testimony routinely becomes evidence against the witness. Heres how it happens. The SEC asks you about transactions you worked on. You explain what you did, what you knew, who you reported to, what information you had. Standard background questions. But embedded in those answers are admissions about YOUR knowledge, YOUR actions, YOUR role in conduct that might be problematic. You didnt realize it was problematic at the time. The SEC did. Thats why there investigating.

Or you give an answer that conflicts with documents. You say you werent aware of certain information. Then investigators pull up an email thread were you were copied on that exact information six months earlier. Now youve made an inconsistent statement. Was it an honest mistake – you forgot about an email from months or years ago? Or was it an intentional misstatement to minimize your involvement? The SEC dosent have to decide which. The inconsistency itself is evidence. It becomes part of there investigation file. If they eventually bring charges, that inconsistent statement becomes exhibit evidence.

The witness-to-target pipeline is real. You come in for testimony about someone elses conduct. Your answers reveal YOUR liability. Maybe you had knowledge you werent supposed to have. Maybe you approved something you should have questioned. Maybe you participated in communications that demonstrate awareness of problematic activity. The investigation just expanded. The interview that was supposed to be about your boss’s trading decisions is now about wheather you aided and abetted securities violations.

And you cant take it back. Once you testify under oath, that testimony is locked. The transcript is a permanent record. If you later realize your answers created problems for yourself, its too late to clarify or correct. Anything you say in subsequent interviews or testimony has to be consistent with what you already said, even if what you already said wasnt accurate or complete. Your stuck with it. This is why expereinced attorneys advise treating every SEC subpoena – even ones explicitly described as “witness only” – as if your a potential target. Because the distinction between witness and target can dissapear during a single interview.

The FINRA Permanent Record

Everyone focuses on the immediate consequences of an SEC investigation – the penalty amount, wheather you can keep your license, how long any industry suspension lasts. Those matter. A $2 million fine matters. A two-year bar from the securities industry matters. But theres a consequence that outlasts all of those: BrokerCheck.

FINRAs BrokerCheck is a public database that shows the regulatory history of everyone registered in the securities industry. Anyone can search it – you dont need credentials or clearance or even a reason. Potential employers search it during hiring. Compliance departments search it automaticaly when processing registrations. Clients search it before deciding wheather to work with you. Journalists search it when writing articles about securities professionals. And what appears on BrokerCheck stays there permanantly.

SEC enforcement actions appear on BrokerCheck wheather you settle or fight, wheather you admit wrongdoing or settle without admission, wheather the penalties are large or minimal. The fact that the SEC brought an action appears. The allegations appear. The resolution appears. Theres no expungement process. You cant petition to have old disciplinary actions removed. You cant seal records even if you successfully defend against charges. Everything stays permanantly searchable.

This creates career consequences that extend decades beyond the investigation itself. Many securities firms have automatic disqualification policies – they wont hire anyone with an SEC enforcement action on there BrokerCheck record, regardless of the specifics or how long ago it happened. Clients in high-stakes transactions specificaly request brokers or advisors with clean regulatory records. Even if you successfully rebuild your career at a firm that will hire you, that BrokerCheck record creates a ceiling. Partnership tracks close. Senior positions become unavailable. Client-facing roles get restricted.

And you cant escape it geographicaly. BrokerCheck is nationwide. You cant move to a different state and start fresh. You cant switch to a different firm and leave the record behind. Every securities firm, in every state, checks the same BrokerCheck database. A mistake in how you responded to an SEC subpoena in New York will appear on background checks in California, Texas, Florida, every state, for the rest of your career. Your 35 years old. That record will still be searchable when your 65.

So when attorneys say “take the subpoena seriously,” this is part of what they mean. Not just the immediate investigation and penalties. The permanent public record that follows you for 30 or 40 years. The automatic disqualifications. The career ceiling. The client rejection. One series of decisions about how to respond to a subpoena creates consequences that outlast the investigation by decades.

The Selective Production Trap

Guess what? People think they can be strategic with document production. Give investigators the good documents – the ones that show you following procedures, asking compliance questions, acting carefully. Hold back the problematic ones – the emails were you expressed concerns that were ignored, the conversations about cutting corners, the internal discussions about questionable practices. Let them find those documents somewhere else if there so important. Make them work for it.

This is how people catch obstruction of justice charges that carry more prison time than the underlying securities violations. Selective production – intentionaly withholding documents you know are responsive to a subpoena – is obstruction under 18 U.S.C. § 1505. The penalty is up to five years in federal prison. And its often easier for prosecutors to prove than the original securities violations they were investigating.

Heres how they prove selective production. They subpoena your colleagues, your counterparties, your companys email servers. Someone else produces the email thread you withheld. Or the SEC subpoenas your email provider directly under the Stored Communications Act – they can get your emails without your consent. Suddenly investigators have an email you didnt produce, and they can prove you had access to it. Thats direct evidence of intentional withholding.

Forensic examination makes selective production even more dangerous. Email systems maintain metadata showing when messages were sent, recieved, deleted, moved to folders. If you produced 47 emails from a particular thread but withheld three that were unfavorable, forensic analysis can show the gap. If you printed certain emails to PDF for production but left others out, forensic examination of your computer can show what existed at the time of the subpoena and what you chose to exclude.

And now your defending two investigations. The original securities violation inquiry, plus a seperate obstruction charge. The obstruction charge dosent require proving the underlying securities violations. They can convict you of obstruction even if they never charge you with the original conduct being investigated. You thought you were being clever about document production. You commited a seperate federal crime thats easier to prove than whatever they started investigating.

This is why expereinced securities attorneys immediatly implement document holds, conduct comprehensive searches using broad keyword terms, and err on the side of overproduction rather than underproduction. Its why they document the entire document collection and review process – showing investigators exactly what searches were run, what criteria were used, what was found and why specific documents were or werent produced. Not because overproduction is fun or cheap (its neither). Because selective production is a federal crime that transforms a civil regulatory investigation into a criminal prosecution.

What Happens If You Ignore the Subpoena

Some people think ignoring an SEC subpoena is an option. Just dont respond. Let it sit. There busy, maybe theyll move on to other priorities. Maybe the investigation will close on its own. Maybe this will just go away. It wont. And the consequences of ignoring a federal subpoena are severe and escalating.

First, the SEC files an enforcement action in federal court seeking to compel your compliance. That filing is public, as discussed earlier, which means the investigation is no longer confidential. But the immediate consequence is worse than publicity – its a federal court order requiring you to comply with the subpoena. Once a federal judge orders compliance, ignoring that order is contempt of court under 18 U.S.C. § 401.

Civil contempt means daily fines that continue accumulating until you comply. These arent nominal amounts. Courts regulary impose $1,000 per day or more. Every single day you continue refusing to comply, another $1,000 gets added to what you owe. This isnt a penalty that gets paid at the end – its coercive. The point is to make continued refusal so expensive that compliance becomes the only rational choice. Some courts have imposed $5,000 or $10,000 daily fines in cases involving significant document productions or high-stakes investigations.

Criminal contempt is jail time. Actual incarceration for refusing to comply with a federal court order. This isnt theoretical – federal judges regulary impose criminal contempt sanctions including imprisonment. And criminal contempt dosent require proving intent or willfulness in the same way other crimes do. The question is simply: did you violate a clear court order? If yes, criminal contempt. How long did you refuse? That affects the sentence.

Then theres obstruction of justice as a seperate charge. If prosecutors can show you wilfully refused to comply with the subpoena with intent to impede the investigation, thats obstruction under 18 U.S.C. § 1505. Five years maximum federal prison sentence. And unlike contempt charges that can be purged by eventually complying, obstruction charges remain even after you finaly respond to the subpoena. The crime was the refusal itself, not the continuing refusal. You cant undo it by cooperating later.

And all of this is before they even address the underlying securities violations they were investigating. Youve added contempt charges and possibly obstruction charges on top of whatever they originaly wanted to ask you about. The investigation that might have resulted in civil penalties just became a criminal prosecution. The response deadline you thought was just a suggestion became the trigger for federal criminal charges.

Constitutional Protections: The Fifth Amendment

The Fifth Amendment protects against self-incrimination. You cannot be compelled to provide testimony that could expose you to criminal prosecution. This protection applies to SEC investigations even though there nominaly civil proceedings. If questions would require you to admit facts that could support criminal charges, you can invoke your Fifth Amendment right to remain silent.

But Fifth Amendment protection has limits in the SEC context. You can assert the Fifth Amendment to refuse to answer questions or provide testimony. You generaly cannot assert it to avoid producing documents that already exist. The “act of production” doctrine provides some protection – if the act of producing documents itself would be testimonial (confirming the documents exist, you possess them, and there authentic), you can potentially assert Fifth Amendment protection. But courts interpret this narrowly. They usualy compel document production even when the documents contain incriminating information.

Heres were it gets complicated. If you assert your Fifth Amendment right during SEC testimony, you might avoid criminal exposure from that testimony – but the SEC can still use your refusal to answer questions as the basis for civil sanctions. They can bring administrative proceedings, impose industry bars, assess civil penalties. You protected yourself criminaly but not civilly. Wheather that trade-off makes sense depends entirely on wheather criminal prosecution is a real risk.

This is why the existence of parallel DOJ investigation changes Fifth Amendment calculations completly. If its only the SEC – only civil regulatory enforcement – then cooperation despite the minor criminal risk might make sense to minimize civil penalties. But if DOJ is activly investigating with the possibility of criminal charges, full invocation of Fifth Amendment rights becomes essential regardless of civil consequences. Paying an SEC civil fine is survivable. Federal prison time is not.

Expereinced securities defense attorneys make this determination before any testimony or document production. They assess wheather criminal prosecution is likely, wheather DOJ is already involved, what specific criminal statutes might apply, and what evidence exists. Only after that assessment can they advise wheather to cooperate fully, invoke Fifth Amendment rights selectively on certain questions, or assert blanket Fifth Amendment protection. Getting this wrong – cooperating when you should have asserted rights, or asserting rights when cooperation would have been smarter – creates consequences you cant undo later.

What You Should Actualy Do

Document the exact date and time you recieved the subpoena. Not approximately, not “sometime last week” – the specific date and time. Your response deadline runs from receipt. If it came by certified mail, keep the receipt. If someone handed it to you, write down when and were. If it arrived electronically, screenshot the timestamp. This isnt paranoia. This is evidence youll need if theres any dispute about wheather you responded timely.

Do not contact the SEC before speaking with an attorney. The subpoena includes a contact name and number for the SEC staff attorney handling the investigation. Do not call them. Do not email to confirm receipt. Do not have your assistant contact them with questions about the deadline. Every communication with SEC staff becomes part of the investigation record. Anything you say – even informal preliminary conversations – can be used as evidence. The staff attorney is not there to help you. There investigating potential securities violations. Talk to your own lawyer first.

Hire an attorney who specializes in SEC investigations, not a general corporate lawyer who handles your business contracts. Securities investigations require specific expertise – knowledge of SEC enforcement procedures, relationships with SEC staff that allow productive negotiations about scope and timing, understanding of how cooperation decisions affect penalty calculations, experiance determining when DOJ criminal parallel investigations exist. Your regular business attorney may be excellent at transactions or contracts and completly wrong for this situation.

Implement document preservation immediatly. Dont wait to talk to your attorney. Dont wait to understand what the investigation is about. The moment you recieve a subpoena, preservation obligations begin. Send a preservation notice to everyone at your company or in your department who might have relevant information. Suspend email auto-delete policies. Stop backup tape rotations. Preserve text messages, voicemails, chat logs. Document what preservation steps you took and when. If spoliation allegations arise later, youll need evidence that you took preservation seriously from the beginning.

Determine wheather DOJ is involved before making cooperation decisions. This is the first strategic question your attorney should address. Are there signs of parallel criminal investigation? Has the SEC mentioned DOJ involvement? Did you recieve subpoenas from multiple agencies? Do the SECs questions focus on your knowledge and intent rather than just actions? If DOJ is involved, your cooperation strategy changes completly. What reduces SEC civil penalties might provide evidence for criminal prosecution.

Negotiate timeline extensions if you need them. The 30-day default response deadline is not always mandatory. Your attorney can contact the SEC staff attorney and request extensions, especialy for complex document productions or if you need time to conduct privilege reviews. The SEC often grants reasonable extension requests – but “reasonable” means you asked before the deadline expired and you provided legitimate reasons. Waiting until day 29 to ask for an extension because you didnt start looking for documents until then will not get a sympathetic response.

If you do produce documents, document your production process. What search terms did you use? What email accounts and date ranges did you search? Who conducted the review? What criteria determined which documents were responsive? Create a written record of this process. If questions arise later about wheather your production was complete, youll need evidence showing you conducted reasonable searches and made good-faith production decisions. This also protects against selective production allegations.

Take this seriously. Not “hire a lawyer and hope it goes away” seriously. Take it “this could determine wheather I face civil penalties or criminal charges” seriously. The decisions you make in the next 30 days will impact the next 2-5 years of investigation. The testimony you provide or dont provide, the documents you produce or withhold, the cooperation you offer or refuse – all of it gets analyzed, scored, and used to determine outcomes. Most people who recieve SEC subpoenas underestimate how serious they are until its too late to make different choices. Dont be one of them.