A more thorough explanation:

A Wells Submission is a response to a Wells Notice, which is a warning from the U.S. Securities and Exchange Commission (SEC) of possible enforcement action against a person or business. The Wells Submission gives the person or business the chance to present facts and legal arguments to convince the SEC that no action should be taken.

Imagine that a company receives a Wells Notice from the SEC, which alleges that the company has violated securities laws. The company can then submit a Wells Submission to the SEC, which might include evidence and arguments to show that the allegations are unfounded or that the company has already taken corrective action.

Another example could be an individual who receives a Wells Notice for insider trading. The individual can then submit a Wells Submission to the SEC, which might include evidence and arguments to show that they did not have access to insider information or that their actions were not illegal.

These examples illustrate how a Wells Submission can be used to defend against potential enforcement action by the SEC. By presenting evidence and arguments, the person or business can try to convince the SEC that no action should be taken.