Insider Transaction and Beneficial Ownership Reporting – An Enforcement Reminder

On September 25, 2024, the Enforcement Division announced settled actions against 23 companies and individuals relating to Section 16 and Section 13 reporting.  The various actions involved:

Failure of individuals to file Section 16 reports;

Failure of companies to report delinquent Section 16 reports; and

Failure of companies to file Forms 13D, 13G, 13F, and Section 16 reports.

The companies and individuals involved paid fines totaling $3.8 million.  The Enforcement Division included a link to a September 27, 2023 announcement of a similar sweep involving 11 cases, making it clear that this continues to be a focus of their work.

As always, your thoughts and comments are welcome.

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