Upon a second reading of the CFR, I think they have 20 business days to notify the ALJ. In 15 days, he and the SEC must have reached a signed agreement but they have 5 extra days to notify the judge. The section is confusing because they use the word "Commission" in 2 different ways, once to mean the enforcement arm of the SEC and once to mean the ALJ.
I still am hoping the deal falls thru because I want to watch some of the witnesses testify against him in Manhattan.