According to SEC: "Lehman held out its equity research as providing independent stock recommendations and independent analysis of stocks based on the investment merits of the stocks being evaluated. In fact, Lehman's research analysts were, at times, confronted with pressures and conflicts of interest stemming from Lehman's desire to obtain investment banking business from covered companies."

According to the SEC: "The Securities and Exchange Commission announced today that it has settled charges against Lehman Brothers Inc., a New York-based brokerage firm and investment bank, arising from an investigation of research analyst conflicts of interest. This settlement, and settlements with nine other brokerage firms, are part of the global settlement the firms have reached with the Commission, NASD, Inc., the New York Stock Exchange, Inc. ("NYSE"), the New York Attorney General, and other state regulators. "

On March 19, 2010, the SEC published a litigation release announcing that the Honorable William H. Pauley issued an order approving modifications to the final judgments entered against Lehman Brothers, Inc. and the other firms covered by the Global Research Analyst Settlement.

On December 5, 2025, the SEC stated that: "[It] consented to modifications to the October 2003 . . . and September 2004 . . . final judgments against settling firms still covered by the Global Research Analyst Settlement, a global settlement of SEC and other enforcement actions against twelve investment banks and two individuals. The modifications are subject to court approval."

The SEC stated: "[T]he Securities and Exchange Commission (SEC) consents to the relief sought by the motions and agrees that the final judgments should be modified as reflected in the proposed orders submitted by each respective Defendant. . . . Based on these unique facts and circumstances, the SEC believes modification of the Judgment is in the public interest."