Securities and Exchange Commission Historical Society
Special Exhibit

Irving M. Pollack: Father of the SEC Division of Enforcement

Irving M. Pollack (April 8, 1918 – July 1, 2016)

Throughout his 34-year career at the SEC, Irving “Irv” Pollack was a voice for the staff and an advocate for enforcement. Pollack graduated from Brooklyn law school, served in the Army Air Force and joined the Commission in 1946. Pollack worked his way through the general counsel’s office to the Division of Trading and Markets, where he became Director in 1963, and began to assist the SEC Regional Offices in the enforcement efforts for which they were largely responsible at that time. With creation of the Enforcement Division in 1972, Pollack had the opportunity as its first Director to act on his conviction that vigorous enforcement was essential:

“Unless you have good regulation, good supervision and good enforcement, you are not going to accomplish your task. You have three parts really as I see it to an overall program.” (Fireside Chat - SEC Division of Enforcement, September 19, 2008)

The initial Division was instilled with a sense of “mission” and a creative approach to key limitations like budget, the lack of remedies and at times, legal principles.

“In the other civil area, there weren’t individual cases, but we established the restitution, disgorgement, the ancillary remedies, and that was critical. We pushed that way to where it is, and I think now you see it’s accepted today. In our days it was heavily litigated.” (Irving Pollack Oral History, January 16, 2002

In his three decades in the Commission, Pollack became known as a principled, quintessential staffer at a time when they could greatly influence the Commission’s overall program. Indeed, Richard Nixon may have appointed Pollack to the Commission in 1974 in part in order to restore morale among staffers disillusioned by the Brad Cook scandal:

“It's more important for the Commission when it is attempting to impose on its regulatory people a high standard of conduct it has to be above that in its own performance.” (*Roundtable on Enforcement, September 5, 2002)

After leaving the commission, Pollack continued to apply the high standards that he had set years earlier in helping firms with compliance efforts including administering landmark shareholders settlements.

“I used to say when people would raise the question with me: Is it legal to do something. Is it legal to do this? I said, that’s the wrong question. We have to ask is it fair, is it proper to do it. Whether you can legally do it or not, as a government agency, we can’t tolerate this. We have to have the highest standard. You don’t do it if you don’t think it’s fair.” (*Irving Pollack Oral History, January 16, 2002)

In a speech marking the agency’s 50-year anniversary in 1984, Pollack reflected that he (and others) “recognized the important contribution [the SEC] was making to the sound development and growth of the capital markets, unequaled anywhere in the world.” His rationale was simple:

“The Commission never lost sight of its primary mission i.e., to serve and protect the interests of investors and to encourage the maintenance of fair and honest markets. To achieve these objectives, it designed and employed flexible, dynamic and ingenious programs. It made maximum use of the private sector, through cooperative or self-regulation and otherwise, to carry out its functions effectively. It made imaginative use of its regulatory and enforcement powers and the “shotgun behind the door” to: 1. foster quality performance by those providing access to or playing major roles in the securities markets, 2. create a respect for the Commission’s authority, 3. instill and reinforce a recognition among its constituents that compliance with the securities laws was not only legally required, but also good business.” (Irving Pollack – “The SEC’s First Fifty Years”- Summary of Remarks, Major Issues Conference)


Irving M. Pollack Award

Pollack Award Certificate
Pollack Award Certificate

In 1981, the year following his departure for the private sector after 34 years of distinguished service as a staff member and Commissioner, the SEC established an annual award in Pollack’s name. The award credits employees whose own tenure is marked by the traits for which Pollack was most respected and admired:

Honors an individual or team whose performance at the SEC is marked by fairness and compassion in dealings with the public and staff; scholarship and professional expertise in execution of their legal duties; and adherence to the highest standards of personal and professional integrity. To be eligible, the individual or team members must have at least 10 years of service at the SEC.

Irving Pollack was a former Trustee and loyal supporter of the Historical Society, and he remained active in securities-related events up to his death in 2016 at 98.


The Society’s museum collection contains numerous documents, oral histories, programs and photos that keep Irving Pollack’s legacy alive. Below is a selection of relevant materials. You will find many additional items with a simple word search.

Photo Gallery

April 3, 2018

Jann Sidorov, Jack Sidorov, Joan Pollack Liggett, Judge Stanley Sporkin, Judith Sporkin, Walter Schwartz; Janet Pollack Schwartz, Daniel Sporkin

April 3, 2018

Jann Sidorov, Laurence Storch, Jack Sidorov, Joan Pollack Liggett; Judge Stanley Sporkin; Walter Swartz; Janet Pollack Swartz

June 25, 2009

(standing) Steuert Thomsen and Noah Berlin; (seated) Linda Thomsen, Paul Mason, Irving Pollack, David Silver and Daniel Goelzer

June 2, 2004

Isaac C. Hunt, Jr., Steven Wallman, Peter Unger and Irving Pollack

September 25, 2002
1979

Roberta S. Karmel, Philip A. Loomis, Jr., U.S. Supreme Court Chief Justice Warren E. Burger, John R. Evans, Harold M. Williams and Irving M. Pollack.
(Courtesy of Roberta Karmel )

1979

Roberta S. Karmel, Harold M. Williams, Philip A. Loomis, Jr., Irving M. Pollack and John R. Evans

1967

Presentation of Distinguished Service Award

Related Museum Resources

Papers

September 21, 1959
transcript pdf (Courtesy of the National Archives and Records Administration)
1963
document pdf collection (Courtesy of Stuart Kaswell; made possible through a gift from the family of Milton H. Cohen)
September 4, 1963
transcript pdf (All rights are owned exclusively by NYSE Euronext copyright 2007 NYSE Euronext, All Rights Reserved, Courtesy New York Stock Exchange Archives)
October 5, 1965
transcript pdf (Courtesy of National Archives and Records Administration)
May 23, 1966
image pdf (Courtesy of the National Archives and Records Administration)
June 30, 1966
document pdf (Courtesy of Eugene Rotberg)
August 8, 1966
document pdf (Courtesy of Eugene Rotberg)
January 19, 1967
transcript pdf (Courtesy FINRA)
January 20, 1967
document pdf (Courtesy of Eugene Rotberg)
February 24, 1967
document pdf (Courtesy of Eugene Rotberg)
April 21, 1967
transcript pdf (All rights are owned exclusively by NYSE Euronext copyright 2007 NYSE Euronext, All Rights Reserved, Courtesy New York Stock Exchange Archives)
May 19, 1967
document pdf (Courtesy of Eugene Rotberg)
June 16, 1967
document pdf (Courtesy of Eugene Rotberg)
November 20, 1967
document pdf (Courtesy of Eugene Rotberg)
July 2, 1968
transcript pdf (Courtesy of the National Archives and Records Administration)
August 21, 1968
transcript pdf (Courtesy of New York Stock Exchange Archives)
May 25, 1970
image pdf (Courtesy of the National Archives and Records Administration)
June 11, 1970
transcript pdf (Courtesy of the National Archives and Records Administration)
October 13, 1971
transcript pdf (Courtesy of the Chicago Board Options Exchange Archives)
March 1974
document pdf (Courtesy of Richard Rowe)
February 17, 1977
transcript pdf (Courtesy of the Jimmy Carter Library and Museum)
May 2, 1978
image pdf (Courtesy of the estate of John R. Evans; made possible through a gift from Quinton F. Seamons)
1984
document pdf (Courtesy of Paul Gonson)
May 4, 1984
document pdf (Courtesy of Paul Gonson)
April 9, 1987
transcript pdf (Courtesy of National Archives and Records Administration)
September 25, 2002
document pdf
June 14, 2006
document pdf

Photos

1967

Presentation of Distinguished Service Award

1967

(front row) Donald J. Stocking, William Green, Francis Wheat, Hugh Owens, Manuel Cohen, Hamer Budge, Richard Smith, Thomas B. Hart, Arthur E. Pennekamp; (second row) Orval L. DuBois, W. Victor Rodin, David L. Ratner, Andrew Barr, Mahlon M. Frankhauser, Gerald E. Boltz, James E. Dowd, Alexander J. Brown, Jr., James E. Newton, Richard V. Bandler, Solomon Freedman, Irving M. Pollack, Roger S. Foster, Loughlin F. McHugh, Alfred Letzler, Walter P. North; (third row) Ralph L. Bell, Frank J. Donaty, Harry Pollack, Charles E. Shreve, Thomas W. Rae, David Ferber, Philip A. Loomis, Jr., Edmund H. Worthy, Robert H. Bagley, John A. Dudley, Eugene H. Rotberg, Lindsay J. Millard, Aaron Levy, Ernest L. Dessecker, William E. Becker

(Courtesy of Frances Green Oliver )
1974

A.A. Sommer, Jr., Philip A. Loomis, Jr., Ray Garrett, Jr., John R. Evans and Irving M. Pollack

November 24, 1975

A. A. Sommer, Jr., Philip A. Loomis, Jr., Roderick M. Hills, John R. Evans and Irving M. Pollack

1977

Irving M. Pollack, Philip A. Loomis, Jr. Harold M. Williams, John R. Evans and Roberta S. Karmel

November 1977

Philip A. Loomis, Jr., Harold M. Williams, John R. Evans and Irving M. Pollack

1979

Roberta S. Karmel, Harold M. Williams, Philip A. Loomis, Jr., Irving M. Pollack and John R. Evans

1979

Roberta S. Karmel, Philip A. Loomis, Jr., U.S. Supreme Court Chief Justice Warren E. Burger, John R. Evans, Harold M. Williams and Irving M. Pollack

(Courtesy of Roberta Karmel )
Fall 2002

Paul Atkins, Cynthia Glassman, Harvey L. Pitt, Harvey Goldschmid and Roel Campos

September 25, 2002
November 2002

Isaac C. Hunt, Jr., Irving M. Pollack, David S. Ruder, Harvey L. Pitt, Laura S. Unger, J. Carter Beese and Roderick M. Hills

June 2, 2004

(left to right) Roderick Hills, J. Carter Beese, Laura Unger, G. Bradford Cook, Irving Pollack, Harvey Goldschmid, Aulana Peters, Mary Schapiro, Richard Breeden, David Ruder, Cynthia Glassman, Isaac Hunt, William Donaldson, Roberta Karmel, Richard Roberts and Steven Wallman

June 2, 2004

Isaac C. Hunt, Jr., Steven Wallman, Peter Unger and Irving Pollack

September 23, 2008
June 25, 2009

University of Georgia Law School table: (standing) Margaret Sachs, Usha Rodrigues, James L. Henderson III, Luis Aguilar, Kevin Conboy and Paul Hastings; (seated) Stephen Roth, Daniel White, Michael Sharp, Scotty Mann and Rebecca White

April 3, 2018

Jann Sidorov, Jack Sidorov, Joan Pollack Liggett, Judge Stanley Sporkin, Judith Sporkin, Walter Schwartz; Janet Pollack Schwartz, Daniel Sporkin

April 3, 2018

Jann Sidorov, Laurence Storch, Jack Sidorov, Joan Pollack Liggett; Judge Stanley Sporkin; Walter Swartz; Janet Pollack Swartz

Oral Histories

21 May 2015

David Becker

09 August 2006

John Fedders

22 June 2004

Justin Feldman

  • - Part 1
  • - Part 2
  • - Part 3
  • - Part 4
  • edited transcript (pdf)
08 May 2008

Ralph Ferrara

13 August 2003

James Foster

08 July 2005

Roberta Karmel

13 September 2001

Milton Kroll

14 January 2003

Alan Levenson

25 July 2006

Theodore Levine

22 July 2008

Richard Phillips

16 January 2002

Irving Pollack

  • - Part 1
  • - Part 2
  • - Part 3
  • edited transcript (pdf)
27 May 2015

David Ruder

01 October 2001

A.A. Sommer, Jr.

04 April 2005

Theodore Sonde

23 September 2003

Stanley Sporkin

19 January 2006

Harold Williams

Programs

23 September 2008

Fireside Chat - SEC Division of Enforcement

Moderator: Theresa Gabaldon

Presenter(s): Irving Pollack

29 May 2003

Roundtable on Regional Administrators

Moderator: Irving Pollack, Stanley Sporkin

Presenter(s): Gerald Boltz, Jack Bookey, Robert Davenport, Kevin Duffy, Randall Fons, Leonard Rossen, William Schief, Michael Stewart, Robert Watson

25 September 2002

Roundtable on Enforcement

Moderator: Irving Pollack, Stanley Sporkin

Presenter(s): Theodore Altman, David Doherty, Benjamin Greenspoon, Theodore Levine, Alan Rosenblat, Thomas Rae, Richard Rowe, David Silver, Theodore Sonde, Wallace Timmeny

04 October 2001

Roundtable on 1963 Special Study

Moderator: Brandon Becker, Irving Pollack

Presenter(s): Robert Birnbaum, Milton Cohen, Meyer Eisenberg, Norman Poser, Eugene Rotberg, Ralph Saul, Fred Siesel, David Silver, Stanley Sporkin

Permission for Use

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