$3.8 Million In Penalties for Late Beneficial Ownership & Insider Transaction Reports (09/25/24)
The SEC charged 23 entities and individuals for failures to timely report information about their holdings and transactions in public company stock. Two public companies were also charged for contributing to filing failures by their officers and directors and failing to report their insiders’ filing delinquencies as required. The charges stem from SEC enforcement initiatives focused on Schedules 13D and 13G reports and Forms 3, 4, and 5 that certain corporate insiders are required to file. This sweep emphasizes the importance of effectively monitoring positions in which an adviser or fund manager, either individually or together with affiliates, beneficially owns 5% or more of an issuer. The summary highlights various nuanced facts and details from these cases which can be instructive to readers in assessing their risks and enhancing their policies and procedures.
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