On September 27, 2023, the Enforcement Division announced settled enforcement orders against six individuals and five companies based on Section 16 and Forms 13D and 13G reporting failures.  The individuals and  companies paid fines ranging from $115,000 to $200,000.  Sanja Wadhwa, Deputy Director of the SEC’s Division of Enforcement, said:

“Today’s enforcement action should serve to remind SEC filers that reporting obligations under the securities laws are not optional, and there are consequences for failing to file required forms in a timely manner.”

This enforcement sweep is very similar to a September 2014 sweep.  You can read more in this Press Release, where you can find links to the individual orders.

As always, your thoughts and comments are welcome!

In a prior blog post, we reviewed a September 8, 2023, Enforcement Order against Monolith Resources, LLC based on the company violating the SEC’s whistleblower protection rules.

Less than two weeks later, on September 19, 2023, the Enforcement Division added to the growing list of these cases with an announcement that CBRE, Inc., a wholly-owned subsidiary of NYSE-listed CBRE Group, Inc., had also violated the whistleblower protection rules.   In its separation agreements CBRE Inc. had included language requiring employees to attest “that they had not filed a complaint against CBRE with any federal agency.”  After the SEC commenced its investigation, the company took strong remedial steps.  In settling the case CBRE, Inc. paid a civil penalty of $375,000.

You can read more in the related SEC Order.

As always, your thoughts and comments are welcome!