Here’s how the SEC themselves talk about their thought process around settlements https://www.sec.gov/newsroom/speeches-statements/clayton-statement-regarding-o

Here’s how the SEC themselves talk about their thought process around settlements https://www.sec.gov/newsroom/speeches-statements/clayton-statement-regarding-offers-settlement https://www.sec.gov/newsroom/speeches-statements/clayton-sta... It’s basically usually some mix of fine and restitution, with the bulk going to restitution in these sorts of cases but with more fine in cases where the defendant should have known better (eg settlements with big banks) but the actual nominal loss to investors is lower than the regulator believes the firm should have to pay up.