The commission needs to question Cox hard about his revolving door and how he could let so much fraud go without enforcement action.
Investigations may not produce results for a few years, and some inquiries will end without any enforcement action being taken.
Michael Adler, a spokesman for the Moody's Corporation, the parent of Moody's Investors Service, said the company was pleased the matter had been resolved without an enforcement action.
At a Congressional hearing, the S.E.C.'s head of enforcement, Linda Thomsen, said the agency started an investigation of Mr. Madoff's business in 2006 but closed it early in 2008 without recommending enforcement action.
Gradient made public Wednesday a letter from an S.E.C. enforcement official, Marc J. Fagel, informing lawyers for Gradient that the investigation had been terminated without any enforcement action being recommended by the agency staff.
The SEC opened a preliminary inquiry into IBM and promptly closed the matter without taking enforcement action.
The S.E.C. has defended the agreements, saying that it allows the commission to bring enforcement actions against companies and extract penalties without having to bear the costs and the uncertain outcome of a trial.
It's extremely dirty work that Exide was allowed to perform for 30 years on a temporary permit without adequate, modern environmental and health protections, and despite repeated enforcement actions and penalties.
The requirement, in general terms, was set by Congress, but the board's specific proposal cannot go into effect without the approval of the Securities and Exchange Commission, which reviews its major rules and enforcement actions.
The senators wrote, "We strongly believe that the department should not be taking these enforcement actions after changing its interpretation of the applicable law without the benefit of proper notice".
