On September 26th, SEC Chairman Mary Jo White gave a speech entitled "Deploying the Full Enforcement Arsenal" in which she explains when the Commission will require admissions in its enforcement actions. Considerations include: the number of investors harmed or the egregious nature of the conduct; the risks posed to the market or investors; the assistance an admission may provide to investors pursuing private cases; and the message which might be sent to the market. Corporate penalties will always be considered in appropriate circumstances and firms should expect to see more mandatory undertakings. Prior to considering corporate responsibility, however, enforcement staff should look first at individual conduct, working out to the entity. She notes, "It is a subtle shift, but one that could bring more individuals into enforcement cases." White Remarks.