Over the years the SEC’s Enforcement Division has brought a number of cases against companies, including J.P. Morgan Securities LLC, CBRE, Inc. and The Brink’s Company, for violating Rule 21F-17(a) of the Securities Exchange Act of 1934.  This section of the Act prohibits companies from taking any action to limit communicating directly with the SEC concerning a possible securities law violation.

In a sign that this kind of violation will continue to be a focus area for the Enforcement Division, this May 22, 2026, Administrative Proceeding Summary announced settled charges against Foot Locker, Inc. for using separation agreements that violated Rule 21F-17(a).  The company entered into a cease and desist order and paid a $148,000 civil penalty.

As always, your thoughts and comments are welcome!