I agree with most of your post, but I don't think the SEC cares. With their ridiculous increase in suspensions they are fully aware that some companies will end up unjustly in the line of fire. They also know they have no one to answer to and if a couple of companies every year out of 600+ make it back they couldn't care less imo.

Same as the IRS, they will assess tax, fines and penalties against you until you prove them wrong. Once you do, they don't say anything back, you just stop getting notices to seize your property and they move on to the next, never admitting mistake, never caring and there is nothing anyone can do about it besides complain to their friends.