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.

The SEC consented to modifications to October 2003 and September 2004 final judgments against Lehman Brothers and other investment banks covered by a global settlement of SEC And other enforcement actions against twelve investment banks and two individuals. In 2025, the settling firms filed motions to terminate their remaining undertakings under this settlement and the SEC consented.

Defendants filed an unopposed motion to modify final judgments. The SEC consented to the relief sought, agreeing that the final judgments should be modified. The SEC noted that "unique facts and circumstances" meant modification of the Judgment was in the public interest.