Gibson Dunn has produced a 2011 Year-End Securities Enforcement Update that provides a detailed summary of SEC enforcement actions over the past year.  Gibson Dunn reports that the Enforcement Division reported a record high number of enforcement actions, 735, resulting in more than $2.8 billion in penalties and disgorgement ordered.  The report notes that there was a substantial increase in enforcement actions against investment advisers and broker-dealers, including cases in areas of investment adviser performance disclosure, management fees and compliance.  The summary also discusses the judicial challenge to the SEC's ability to settle cases on a "neither admit nor deny" basis.