On October 7, 2025, SEC Chair Paul S. Atkins gave a keynote address (Address) at the 25^th Annual A.A. Sommer, Jr. Lecture on Corporate, Securities and Financial Law, in which he stressed the importance of the Wells process, whereby the SEC shows potential targets of enforcement cases what it believes to be evidence of violations and allows those parties to make a case against enforcement action. In Atkins’ view, the Wells process offers a crucial guarantee of due process and a bulwark against regulation by enforcement, yet it is underutilized. In keeping with the broad laissez-faire and pro-innovation philosophy that has marked his tenure as SEC chair so far, he called for wider use of the Wells process and for extending the window of time in which the defense can present evidence. This article summarizes the Address, the limits on use of the Wells process that Atkins aims to rectify and key takeaways for private fund managers, with expert commentary from former SEC attorneys. See our three-part series on the Wells process: “Origin and Key Elements” (Jun. 13, 2019); “SEC Enforcement Staff Views of the Process” (Jun. 20, 2019); and “The Pre-Wells Process Versus the Post-Wells Process” (Jun. 27, 2019).