I am the Lorax. I speak for the trees.I speak for the trees, for the trees have no tongues.

--The Lorax, by Dr. Seuss

I don't know at what point I became the Lorax, speaking for the SEC. I certainly didn't set out to be the Lorax, and have been critical of the SEC through the years and recently where I thought it was appropriate (see here and here, for example).

The snowballing criticism of the entire SEC Enforcement Division program by Congress, the media, Harry Markopolos and others, however, has spurred me to defend the Division against what I consider to be unfair charges. Don't get me wrong—the handling of the Madoff case appears to have been a complete debacle. That single case, however, which involved a handful of the Enforcement Division's over 1,000 members, does not mean that the entire Division is inept or corrupt.

To the contrary, the Enforcement Division has had a long history of effective enforcement against financial fraud, insider trading, market manipulation, and other violations of the securities laws. I attempt to make the case that the Enforcement Division is "not guilty" of the more extreme charges against it in this column now available on the front page of Compliance Week and at this link (click here), as well as in my recent interview on Fox News (available here).

I attended the ASECA Annual Dinner on Friday of last week along with hundreds of other former SEC employees. There was a high level of sadness, dismay, and frustration among former and current employees of the SEC at the caricature of a bumbling SEC that is now being being presented to the world by our own Congress and others based on the Madoff case. There was also, however, a great deal of optimism that Mary Schapiro's leadership can help restore the public's confidence in the SEC as an institution.

If no one else is going to be the Lorax against the most unfair attacks against the SEC, I guess I'll need to grow the walrus mustache for a while and step up.