Christopher Cox
28th Chair of theSecurities and Exchange Commission
In office August 3, 2005 – January 20, 2009
President	George W. Bush
Preceded by	William H. Donaldson
Succeeded by	Mary Schapiro
Chair of theHouse Homeland Security Committee
In office January 3, 2003 – August 2, 2005
Preceded by	Dick Armey
Succeeded by	Peter T. King
Chair of theHouse Republican Policy Committee
In office January 3, 1995 – January 3, 2005
Leader	Newt Gingrich Dennis Hastert
Preceded by	Henry Hyde
Succeeded by	John Shadegg
Member of the U.S. House of Representatives fromCalifornia
In office January 3, 1989 – August 2, 2005
Preceded by	Robert Badham
Succeeded by	John B. T. Campbell III
Constituency	40th district (1989–1993) 47th district (1993–2003) 48th district (2003–2005)
Personal details
Born	Charles Christopher Cox (1952-10-16)October 16, 1952 (age 72) Saint Paul, Minnesota, U.S.
Political party	Republican
Spouse	Rebecca Gernhardt
Education	University of Southern California (BA) Harvard University (JD,MBA)

Charles Christopher Cox (born October 16, 1952) is an American attorney and politician who served as chair of theU.S. Securities and Exchange Commission, a 17-yearRepublican member of theUnited States House of Representatives, and member of theWhite House staff in theReagan Administration. Prior to his Washington service he was a practicing attorney, teacher, and entrepreneur.^[1] Following his retirement from government in 2009, he returned to law practice and currently serves as a director, trustee, and advisor to several for-profit and nonprofit organizations.

Cox was born inSt. Paul, Minnesota. After graduating fromSaint Thomas Academy inMendota Heights, Minnesota in 1970, Cox earned a Bachelor of Arts degree theUniversity of Southern California in 1973, following an accelerated three-year course.^[2] He was also a member ofDelta Tau Delta fraternity. In 1977, he earned both anM.B.A. fromHarvard Business School and aJ.D. fromHarvard Law School, where he was an editor of theHarvard Law Review.^[3]

From 1977 to 1978, he served as law clerk to JudgeHerbert Choy of theU.S. Court of Appeals for the Ninth Circuit.^[4]

In October 1978, Cox was paralyzed from the waist down following a serious off-road Jeep accident in the rainforest on theHawaiʻian island ofMolokaʻi. He eventually regained the ability to walk but wore a harness of steel bars and leather straps for six months. He still has two metal screws in his back, and according to a 2005Fortune magazine profile, “has been in pain every day for the past 27 years.”^[5] Since he can't sit for extended periods of time, he has a special desk that allows him to work while standing.^[6]

As a contestant on theNBC-TV game showPassword Plus, Cox won more than $5,000 over multiple appearances.^[5] According to a re-broadcast ofPassword Plus on the cable network GSN, Cox appeared in 1980 and won $5,400 cash.

From 1977 to 1986, Cox was first an associate and then partner with the international law firm ofLatham & Watkins. At the time of his retirement in 1986 he was the Partner in Charge of the Corporate Department in theOrange County office, and served as a member of the firm's national management.^[3] In 1982–83, Cox took a leave of absence fromLatham & Watkins to teach federal income tax atHarvard Business School.^[3]

In 1984, Cox co-founded Context Corporation, which produced daily English reproductions of the leading Soviet state-controlled newspaper,Pravda. The publication was used chiefly by U.S. universities and U.S. government agencies, and was eventually distributed to customers in 26 countries around the world. The company had no connection to the Soviet government.^[7]

During the second term ofRonald Reagan from 1986 to 1988, Cox served assenior associate counsel to the president.^[8] His duties included advising on the nomination of threeSupreme Court justices, the establishment of the Brady Commission following the1987 market crash, and the drafting of legislative reform proposals for thefederal budget process.^[9]

In 1986, following Chief JusticeWarren Burger's confidential message to President Reagan that he planned to step down from the bench, White House CounselPeter Wallison tasked a small team including Cox with thoroughly researching the opinions and judicial philosophies of the leading candidates for the next Supreme Court nomination. The effort focused on judges of theU.S. Court of Appeals who had a substantial record of decisions. After narrowing the field to five or six, the search quickly settled on JudgeAntonin Scalia of theU.S. Court of Appeals for the D.C. Circuit, a recommendation the president accepted.^[10][11]

As a part of his White House responsibilities, Cox also reviewed theFBI files of nominees for presidential appointments.^[12]

WhenHoward Baker took over forDonald Regan aschief of staff in 1987, bringing with himArthur B. Culvahouse Jr. as counsel to the president,First LadyNancy Reagan specifically asked Culvahouse to keep Cox on the White House staff. According to Culvahouse, she and the East Wing staff "liked Chris a lot ... He is a very good lawyer," and his willingness to give up his partnership in a prestigious law firm to join the White House staff only a year before had made an impression.^[13] As senior associate counsel under Culvahouse, Cox became deeply involved in market issues and securities issues including then-pending congressional proposals for legislation oninsider trading,greenmail,junk bonds,golden parachutes andgolden handcuffs,tender offers, andtakeovers.^[12][14]

His work on the White House response to the1987 stock market crash included the formation of the Presidential Task Force on Market Mechanisms and the recruitment ofHarvard Business School professorRobert Glauber, who had been Cox's department chairman during his stint on the faculty there, as its executive director. The Commission provided the definitive autopsy on what happened to the markets onBlack Monday, October 19, 1987, and its aftermath.^[15][12] Coincidentally, eight months prior to the crash, Chief of StaffHoward Baker had asked Cox to write a detailed memo describing the emergency powers that the President might exercise in a market crisis. That landed Cox in an emergency meeting in the chief of staff's office on Black Monday, from which Baker called then-NYSE Chairman John Phelan to urge him to drop his plan to shut down the New York Stock Exchange.^[16]

At the time, some conservatives were pushing for aconstitutional convention to advance abalanced budget amendment, and Cox conducted research on the question. He represented the White House at hearings on the advisability of releasingJohn Hinckley fromSt. Elizabeth's Hospital following Hinckley's attemptedassassination of President Reagan, and led the vetting and research effort that resulted inNorthwestern Law School DeanDavid Ruder being recommended to the president asSEC Chairman in 1987.^[12]

A former soccer player atUSC, as a White House counsel Cox worked with theUnited States Soccer Federation on its proposal to bring theWorld Cup to the United States in 1994. “He was a key. Everybody in the damned government had their fingers in this,” said Eddie Mahe, who ran the U.S. Soccer Federation's 1986 campaign to bring the event to the United States. “Without him, I don’t know that it would have survived.” According to theLos Angeles Times, soccer's governing body was requiring waivers of federal laws and regulations from virtually every agency of the federal government, and in "record time, Cox prepared an executive order directing the agencies to fall in line. Reagan signed it."^[17] On July 5, 1988, the U.S. won the selection bid.^[18] In appreciation, the U.S. team presented Cox with the first jersey to be signed by all 22 members.^[19][12]

Cox was elected to Congress in 1988 from what was thenCalifornia's 40th congressional district. He was re-elected eight more times from thisOrange County-based district, which was renumbered as the 47th District in 1993 and the 48th District in 2003.^[1]

Early in his congressional career, Cox befriended two anti-Communists in Hungary andLithuania who had been prisoners of conscience and who later became presidents of their countries after the end ofSoviet domination. Cox metÁrpád Göncz in 1989, and when Cox was later married, he spent part of his honeymoon in Hungary with then-President Göncz and his wife Mária Zsuzsanna Göntér. Cox met Dr.Vytautas Landsbergis, a professor at the Conservatory of Music inVilnius, in 1989, well before the successful reestablishment ofLithuanian independence. The nightLandsbergis was elected President ofLithuania, he embraced Cox on the tarmac at the airport inVilnius after theSoviet Union had held Cox inEast Berlin for a prolonged period.^[20] In May 1998, Cox was presented with theOrder of the Lithuanian Grand Duke Gediminas, the highest honor the Republic of Lithuania can give to a living noncitizen.^[21]

In 1989, Polish PresidentLech Wałęsa joined Cox in aWashington, DC ceremony marking the enactment of Cox's legislation establishing the Polish-American Enterprise Fund. Together with the Baltic-American Enterprise Fund, the Hungarian-American Enterprise Fund, and seven other enterprise funds in Central and Eastern Europe and the formerSoviet Union, the Cox legislation, incorporated in the Support Eastern European Democracy (SEED) Act, matched U.S. foreign aid with venture capital in the newly free countries of the formerWarsaw Pact. Cox has some fluency in the Russian language.^[22]

In 1994, Cox was appointed by PresidentClinton to the Bipartisan Commission on Entitlement and Tax Reform, which in 1995 published a unanimous report warning that the nation cannot continue to allowentitlement programs to consume a rapidly increasing share of the federal budget.^[23]

Among Cox's notable legislative successes as a Representative was theInternet Tax Freedom Act, a 1998 law prohibiting federal, state, and local governmenttaxation of Internet access and banning Internet-only levies such as email taxes, bit taxes, and bandwidth taxes. WithU.S. Rep.Barney Frank (D-MA) as his chief co-sponsor, Cox authored legislation in 1997 to privatize theNational Helium Reserve, which was then $1.4 billion in debt to taxpayers. As of 2004, this was the third-largestprivatization in U.S. history, surpassing the value of the 1988Conrailprivatization.^[24] Cox also wrote the only law that was enacted over PresidentBill Clinton's veto, thePrivate Securities Litigation Reform Act of 1995, aimed at protecting investors from fraudulent and extortionate lawsuits.^[25]

For 10 of his 17 years in the Congress, from 1995 to 2005, Cox served in the House Majority Leadership as Chairman of the House Republican Policy Committee, the fifth-ranking elected leadership position (behind theSpeaker, theMajority Leader, theMajority Whip, and the Chair of theHouse Republican Conference). He was Chairman of theHouse Committee on Homeland Security, and also Chairman of theSelect Committee on U.S. National Security that produced theCox Report, an indictment of Chinese espionage and of security failures at several U.S.national laboratories.^[1]

When Congress established the Bipartisan Study Group on Enhancing Multilateral Export Controls through federal legislation in 1999, Cox was tapped as co-chairman. The group published a unanimous report in 2001 recommending wholesale modernization of U.S. export controls.^[26] Cox also served as Chairman of the Select Committee on Homeland Security (the predecessor to the permanent House Committee); Chairman of the Task Force on Capital Markets; and Chairman of the Task Force on Budget Process Reform.^[3]

In the spring of 2001, then-Representative Cox was considered by PresidentGeorge W. Bush for a federal appellate judgeship on theU.S. Court of Appeals for the Ninth Circuit. Cox withdrew his name from consideration before a nomination could be made because one of his home state Democratic Senators,Barbara Boxer, objected to him due to his perceived conservatism.^[27][28] The seat that Cox had been considered for was eventually filled by Bush nomineeCarlos Bea.

Cox was nominated by PresidentGeorge W. Bush to be the 28th chairman of theUnited States Securities and Exchange Commission (SEC) on June 2, 2005, and unanimously confirmed by theUnited States Senate on July 29, 2005. He was sworn in on August 3, 2005.

Shortly after becomingSEC Chairman, he was diagnosed with thymoma, a rare form of cancer, and underwent surgery in January 2006 to remove a tumor from his chest. He returned to work "after several weeks recovering from surgery," according to TheAssociated Press.^[29] (The cancer returned 10 years later, but Cox was again given a clean bill of health after surgery and treatment.)^[30]

In May 2008, Cox delivered the Commencement Address atNortheastern University inBoston,Massachusetts.^[31] In April 2008, he received theUniversity of Southern California's highest award, the Asa V. Call Achievement Award, in a ceremony at the Los AngelesMillennium Biltmore Hotel.^[32]

TheHousing and Economic Recovery Act of 2008, enacted in July 2008, gave Cox one of five seats on the Federal Housing Finance Oversight Board, which advises the Director of theFederal Housing Finance Agency with respect to overall strategies and policies regarding the safety and soundness ofFannie Mae,Freddie Mac, and theFederal Home Loan Banks. In September 2008, theU.S. Congress passed andPresident Bush signed theEmergency Economic Stabilization Act of 2008, which placed Cox on the newly establishedFinancial Stability Oversight Board to oversee the $700 billionTroubled Assets Relief Program.

During his tenure, Cox led theCommission to implement new executive compensation rules. Since the early 1990s, support for reform had been growing, urged by the U.S.Financial Accounting Standards Board and others. Relying in part on FASB's recommendations for improved presentation of compensation information, the Cox reforms made it possible for users of financial statements to readily understand how public company executives are compensated. Newly required information included the lump-sum cost of retirement benefits and explanations of why specific stock option grants were approved.^[33]The New York Times observed that theCommission "largely stood its ground amid pressure from compensation specialists, investor advocates, and industry groups." With more than 20,000 comment letters, Cox said, "No issue in the history of theSEC has generated such interest."^[34]

One of his first initiatives was launching a plain English effort, to eliminate legalese in investor communications in favor of clear language that let investors focus on what was important, the better to hold a company's performance up to the light of day. Not only the executive compensation rules,^[35][36][37] but also disclosure rules for investment advisors^[38] and mutual funds—where more than half of U.S. households had their retirement and college savings—were subjected to the plain English requirements.^[39] Under Cox theSEC wrote new rules requiring the $10.6 trillion mutual fund industry to make their prospectuses easier for investors to read, understand, and access.^[40]

Cox defended the 2002Sarbanes–Oxley Act and resisted efforts to repeal it or scale it back legislatively.^[41][42][43] The greatest source of complaint about the law during his tenure was its Section 404, which produced compliance expenses far higher than theSEC under his predecessor had predicted.^[44] Working with thePublic Company Accounting Oversight Board, theSEC under Cox replaced the original auditing standard for Section 404 with a streamlined, more cost-effective version,^[45] and also provided new guidance for management intended to reduce unnecessary costs.^[46] At Cox's direction the agency undertook a nationwide Small Business Cost-Benefit Study^[47] to determine whether, as intended, the new auditing standard and management guidance had made compliance less expensive and better focused the 404 process on control elements that truly matter for companies of all sizes.^[48]

In June 2007 theCommission voted unanimously to repeal the so-called "uptick rule" or"tick test."^[49] The action was not controversial at the time: it was taken after an extensive multi-year study by the Office of Economic Analysis, begun in 2003 underChairman Bill Donaldson.^[50] The study found that the rule—which had never applied onNASDAQ or toECNs and other trading systems—had been rendered ineffective on theNYSE due todecimalization (that is, the reduction of the "tick" increment to a penny, as compared to the 1/8 or 12½¢ that was in effect when the rule was adopted in 1938).^[51] Its repeal later became the subject of much debate, with some advocating its reinstatement. On July 15, 2008, Cox told aU.S. House hearing that theCommission was studying the potential institution of "a price test that could work with an increment of a nickel or dime" or some more meaningful amount.^[52]

Technological modernization of theSEC was a Cox priority throughout his tenure. He introduced new technology for investor disclosure,^[53] compliance analytics,^[54] nationwide investigative work sharing,^[55] and management of funds recovered for investors.^[56] In August 2008 he rolled out the future replacement of theSEC's forms-based disclosure database, calledEDGAR, with a new interactive disclosure system using computer-tagged data in theeXtensible Business Reporting Language (XBRL).^[57] The new system was designed to let future investors easily search, sort, and recombine information to generate reports and analysis from hundreds of thousands of companies and millions of forms.^[58] Under Cox theSEC oversaw the creation of a taxonomy of over 11,000 XBRL data tags that catalog every element ofU.S. Generally Accepted Accounting Principles.^[59] In 2008 theCommission issued rules requiring all publicly traded companies and mutual funds in the United States to tag their financial information.^[60]

Another Cox technology initiative liberalized the proxy rules to allow investors and companies to use Electronic Shareholder Forums—virtual meeting places on the Internet to promote shareholder initiatives, conduct straw polls, apprise a company's directors of critical shareholder concerns, and inform shareholders of management's and directors' views.^[61]

In 2006 theSEC launched a war against Internet financialspam, shutting down trading in companies that touted their stock by clogging investors’ in-boxes. Investor complaints about the practice fell from more than 220,000 per month in December 2006 to 70,000 per month in February 2007; Internet software and services companySymantec credited theSEC with cutting financial spam by 30 percent.^[62]

These technological initiatives were widely supported, with one observer noting that Cox "earned virtually universal plaudits for efforts to modernize technology, transparency, and understandability of corporate reports, and to provide for apples-to-apples comparisons (for the first time ever) of corporate executive compensation."^[63]

The particular needs of senior investors, whose ranks are growing rapidly, was a special Cox focus. In April 2006, theSEC held its first “Seniors Summit”, working withAARP, theFinancial Industry Regulatory Authority, theNorth American Securities Administrators Association, and several state regulators; the conferences are now held annually.^[64] A nationwide sweep examination conducted by theSEC and authorities in seven states found that "free lunch" investment seminars, which draw large numbers of retirees, routinely involved significantfraud.^[65][66] Many were advised to put their retirement funds into equity-indexed annuities, where they could get stock market returns while keeping their money “safe”. But neither these investments, nor the sales agents, were registered with state or federal securities regulators—and investors were frequently unaware that it would be impossible to get their money back for as much as 15 years without paying a stiff penalty.^[67] TheSEC enacted rules in 2008 to protect seniors and other investors from fraudulent and abusive practices in annuities sales.^[68]

During Cox's tenure theSEC significantly expanded its international activity. Between 2005 and 2008, Cox signed supervisory arrangements covering enforcement and regulatory cooperation with regulators in the United Kingdom, France, the Netherlands, Belgium, Portugal, Australia, Germany, Bulgaria, and Norway.^[69] As Chairman of theInternational Organization of Securities Commissions' Technical Committee, he led international efforts to convergeU.S. GAAP andInternational Financial Reporting Standards. In December 2007, the SEC adopted rules to permit foreign issuers to useIFRS without reconciliation to U.S. GAAP. And in November 2008, theSEC issued a roadmap – with clear milestones along the way — that would lead to a Commission decision as early as 2014 on whether or not U.S. public companies should be required to useIFRS.^[70] Cox also initiated a mutual recognition process for foreign regulators, based on an assessment of whether the securities regulatory system in another country produces comparably high-quality results for investors, including in the area of enforcement.^[71] In August 2008 he executed an arrangement^[72] with theAustralian Securities & Investments Commission under which the SEC could approve exemptions allowing Australian-registered securities exchanges to operate in the U.S. without having also to register with the SEC, and U.S. exchanges would have the same privilege in Australia.^[73] As of 2008, the SEC was in mutual recognition discussions with regulators in Canada,^[74] and also in preliminary discussions with the Committee of European Securities Regulators.^[75]

International enforcement also stepped up considerably under Cox.^[76] In 2008, theSEC made 556 requests of foreign regulators for assistance with SEC investigations, many of which were connected to potential wrongdoing in the subprime market.^[77] Among the significant international cases theCommission brought during this period were the highly publicized 2008 charges against Hong Kong-based insider trading inDow Jones prior to its acquisition byNews Corporation.^[78] Under Cox the SEC also brought the largest number of cases in its history charging corporations and their officers with foreign bribery under theForeign Corrupt Practices Act and imposed record penalties for these cases.^[79]

Overall, enforcement was Cox's stated priority beginning in 2005^[80] and throughout his chairmanship.^[81] He moved quickly to settle the debate over whether it was legitimate to impose penalties on corporations, adopting a policy that made clear theSEC "isn't turning out to be the corporate-friendly place that many in the boardroom set were hoping for."^[82] Within theSEC budget, as of 2008, he had increased the share devoted to enforcement to its highest level in 20 years.^[83] Nonetheless, theSEC's overall appropriation was held steady during two of his budget years, first by a Republican and then a Democratic Congress, and it was increased by only 2% in a third year.^[84] These sub-inflation agency budgets, combined with merit pay increases for staff, caused the total enforcement personnel to decline.^[85] Critics attacked the underfunding of theSEC and blamed Cox,^[86] though Congress^[87] and the administration^[88] clearly shared the responsibility. When the agency budget was finally increased in fiscal 2008, he increased enforcement personnel by 4%.^[83]

Beginning early in his chairmanship he focused the agency's enforcement efforts onstock option backdating, an illicit practice that had been exposed after the 2002Sarbanes–Oxley Act changed the rules regarding the reporting ofstock option grants.^[89] Under Cox theSEC investigated more than 160stock option backdating cases,^[90] aided by the fact that the reporting forms forstock option disclosure were among the first to be mandated in “interactive data” format.^[91] Some of these cases were noteworthy for their size: in December 2007 the agency won $468 million in a settlement forstock option backdating against the former chairman and CEO ofUnitedHealth Group.^[92]

Cox also aggressively used the agency's “Fair Funds” authority to distribute funds recovered from securities law violators directly to injured investors.^[93] By February 2008 theSEC had returned more than $3.5 billion to wronged investors, including more than $2 billion in 2007 alone.^[94] To expedite the return of the funds, cut red tape and lower costs, Cox created a new Office of Collections and Distributions.^[95] A few weeks later, in May 2008, the new Office began sending more than $800 million in Fair Funds to harmed investors inAmerican International Group, Inc. (AIG), which settledSEC charges offinancial fraud.^[96] In 2006 theCommission obtained a $350 million penalty fromFannie Mae after accusing it ofaccounting fraud; the penalty was one of the largest inCommission history.^[97] The following year theCommission chargedFreddie Mac withaccounting fraud and recovered a $50 million penalty.^[98]

As the 2008credit crunch spread tomunicipal finance, theauction rate securities market froze, leaving investors without access to their cash.^[99] TheSEC immediately investigated the largest firms in the market and entered into settlements that were the largest in the history of theSEC, amounting to up to $30 billion to injuredinvestors.^[100]

Cox also targetedmunicipal securitiesfraud. In April 2008 theSEC charged five formerSan Diego city officials withsecurities fraud involving billions in undisclosed pension liabilities that had placed the city and taxpayers in serious financial jeopardy.^[101] Throughout his chairmanship he railed against the inadequacy of disclosure to investors in municipal securities, which theSEC does not regulate,^[102] and askedCongress for explicit authority for the agency to do so.^[103] In December 2008, theSEC under his leadership authorized the creation of a free, Internet-accessible repository for municipal finance disclosure.^[104] "With liquidity problems of municipal auction rate securities and rating downgrades of municipal bond insurers contributing to the current credit crisis, the disclosure and transparency of the municipal markets have never been more critical," he said.^[105]

In late December 2008, following the confession by New Yorkinvestment advisorBernard Madoff and the filing ofSEC charges against him alleging a $50 billion fraud, Cox stated that he was "gravely concerned" that "specific and credible evidence" provided to the agency over a period of at least 10 years had not previously been referred to theCommission for commencement of a formal investigation. He ordered an internal investigation by the agency's Inspector General.^[106] The report found that substantive allegations concerning Madoff were first brought to theSEC in 1992.^[107]

Under his leadership, theSEC on September 17 and 18, 2008, imposed a variety of both permanent and emergency restrictions onshort selling in response to the liquidity crisis.^[108] Abusivenaked short selling, in which the seller intentionally fails to deliver the shares sold short in time for settlement, was banned outright, an exception for optionsmarket makers that had been in place for several years was eliminated,^[109] and a new anti-fraud provision, Rule 10b-21, was adopted to give specific enforcement authority in such cases.^[110] In September 2008,short selling of 799 financial stocks was temporarily curtailed^[108] in response to rumors accompanied by heightened short selling activity in the shares of major financial institutions.

On September 26, 2008, Cox ended the 2004 program for voluntary regulation of investment bank holding companies, begun underSEC Chairman William Donaldson and then-Director of Market Regulation (laterSEC Commissioner)Annette Nazareth. The program "was fundamentally flawed from the beginning, because investment banks could opt in or out of supervision voluntarily," Cox said.^[111] A critical report by theSEC inspector general that evaluated the program in light of theBear Stearns near-failure in March 2008 found that while "Bear Stearns was compliant with the capital and liquidity requirements" at the time of its acquisition, "its collapse raises serious questions about the adequacy of these requirements." However, according to the Inspector General, his report "did not include a determination of the cause ofBear Stearns' collapse" or determine "whether any of these issues directly contributed toBear Stearns' collapse." On that subject, the report stated, "we have no evidence linking these significant deficiencies with the cause ofBear Stearns' collapse."^[112][113] Cox criticized the oversight program on the ground that because of its voluntary nature and theSEC's limited statutory authority, the agency could not force changes in the hundreds of unregulated subsidiaries of large investment banks such asGoldman Sachs,Morgan Stanley,Merrill Lynch,Lehman Brothers andBear Stearns as bank regulators could do with bank holding companies. In testimony before Congress on several occasions in 2008, he asked for statutory authority to regulate investment bank holding companies.^[114]

In addition to the fact that theGramm-Leach-Bliley Act did not give theSEC the authority to regulate large investment bank holding companies, Cox noted that investors were vulnerable to other regulatory gaps such as the fact that the $60 trillion market forcredit default swaps was then completely unregulated. "Neither the SEC nor any regulator has authority even to require minimum disclosure", he said.^[111] In testimony and public statements he urgedCongress to enact remedial legislation.^[115]

Cox said that during the buildup of thecredit crisis, when thecredit rating agencies were still unregulated, they gave top credit ratings to financial instruments which packaged risky loans and spread the negative impacts of thecredit crisis more broadly throughout the markets.^[116] Following the first-time SEC registration of thecredit rating agencies in September 2007 under newly enacted legislative authority, he ordered a 10-month examination of the three majorrating agencies that uncovered significant weaknesses in their ratings practices formortgage-backed securities and that called into question the impartiality of their ratings. The results were reported toCongress in July 2008.^[117] TheSEC immediately commenced a rulemaking which concluded on December 3, 2008, with approval of a series of measures to regulate the conflicts of interests, disclosures, internal policies, and business practices ofcredit rating agencies. The regulations were intended to ensure that firms provide more meaningful ratings and greater disclosure to investors concerningcollateralized debt obligations andresidential mortgage-backed securities.^[118]

In an interview withThe Washington Post in late December 2008, Cox said, "What we have done in this current turmoil is stay calm, which has been our greatest contribution—not being impulsive, not changing the rules willy-nilly, but going through a very professional and orderly process that takes into account unintended consequences and gives ample notice to market participants." Cox added that theCommission's decision to impose a three-week ban on short selling of financial company stocks was taken reluctantly, but that the view at the time, including from Treasury SecretaryHenry M. Paulson andFederal Reserve chairmanBen Bernanke, was that "if we did not act and act at that instant, these financial institutions could fail as a result and there would be nothing left to save."^[119] In a December 2008 interview withReuters, he explained that theSEC's Office of Economic Analysis was still evaluating data from the temporary ban, and that preliminary findings pointed to several unintended market consequences and side effects. "While the actual effects of this temporary action will not be fully understood for many more months, if not years ... knowing what we know now, I believe on balance theCommission would not do it again."^[120]

Cox stepped down as Chairman of the SEC at the end of the Bush administration, on January 20, 2009.

Following his tenure at the SEC, Cox returned to his home in Southern California and the practice of law, which had been his pre-Washington profession. He joined the Boston-based international law firm ofBingham McCutchen LLP as a partner in the firm's Corporate, M&A and Securities practice, resident in itsOrange County office, where in 2014 The Best Lawyers in America named him Lawyer of the Year in the Corporate Governance category.^[121] He also served as president ofBingham Consulting LLC, the firm's global strategic consulting business.^[122] Following the November 2014 combination ofBingham and the Philadelphia-based international law firm ofMorgan, Lewis & Bockius,^[123] Cox became a partner ofMorgan Lewis and president of Morgan Lewis Consulting LLC.^[124] Other recent members of Morgan Lewis Consulting include formerArizona Diamondbacks andSan Diego Padres ownerJeff Moorad,^[125] formerNational Labor Relations Board chairmanPhilip Miscimarra, formerNew Hampshire GovernorSteve Merrill, formerCalifornia Governor andU.S. SenatorPete Wilson, formerClintonWhite HouseCabinet SecretaryThurgood Marshall Jr., and formerU.S. Ambassador to Ukraine andGeorge Bush Presidential Library Executive DirectorRoman Popadiuk.^[126] While at Morgan Lewis, Cox was again named by The Best Lawyers in America as Lawyer of the Year in Orange County, this time in the Corporate Law category for 2016.^[127] In February 2020, Cox retired as a partner of Morgan Lewis and as president of Morgan Lewis Consulting, taking the title of counsel at the law firm.^[128]

Cox is a member of the board of directors of Revitate, an investor in real estate, sports, and consumer products,^[129] and of NetChoice, an internet industry association.^[130]He is a life trustee of theUniversity of Southern California^[131] and a member of the advisory boards of New York-based Blue Flame AI^[132] and the Loker Hydrocarbon Research Institute, founded byNobel Prize winnerGeorge A. Olah.^[133] He serves as Chair of theRhodes Scholarship selection committee for Southern California, and is a Senior Scholar in Residence at theUniversity of California, Irvine.^[134] He formerly served on the boards of directors of photonics manufacturerNewport Corporation,^[135] governance, risk, and compliance firm ACA Group,^[136] and health care companiesRxSight, Inc.,^[137]Alphaeon Corporation,^[138] and Calhoun Vision, Inc.,^[139] as well as the advisory boards of private equity firm Starr Investment Holdings,^[140] RevOZ Capital,^[141] the United States Energy Security Council,^[142] and governance, risk, and compliance firmThomson Reuters Accelus.^[143] He is a member of the board of directors of the Forum for Corporate Directors and a past chair.^[144] For ten years, he was a member of the board of directors of theNational Endowment for Democracy,^[145] and of the board of trustees ofChapman University.^[146][147]

The Forum for Corporate Directors honored Cox as a "Director of the Year" in March 2019 in the category of Corporate Governance.^[148] In June 2014, Cox was named a "Father of the Year" by theFather's Day Council and theAmerican Diabetes Association in recognition of his "outstanding contributions to his family, profession and community."^[149]

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• Official Biography – SEC Website
• Christopher Cox Sworn in as SEC Chairman – SECPress Release
• Appearances onC-SPAN
• President Bush Nominates Congressman Cox as SEC Chairman –White HousePress Release
• Speeches and Statements as SEC Chairman
• The changes I've seen – Farewell letter by Chris Cox in theOrange County Register

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