On September 10, 2014, the United States Securities and Exchange Commission (the “SEC”) announced enforcement proceedings against officers, directors and major shareholders and publicly-traded companies for violations related to beneficial ownership filings. The broader lesson of these enforcement actions is that, consistent with Chair White’s “broken windows” enforcement philosophy, the SEC’s threshold for pursuing violations of the securities laws has been lowered. Publicly-traded companies, regulated entities and all those that are subject to the federal securities laws should ensure that they have robust policies and procedures in place to ensure compliance with all applicable reporting requirements.

SEC Institutes Enforcement Action for Failure to Comply with Reporting Obligations -

The SEC alleged violations of reporting requirements under Section 13(d) and Section 16(a) of the Securities Exchange Act of 1934 (the “Exchange Act”) that apply to officers, directors and certain major shareholders of SEC reporting companies. The SEC’s enforcement sweep resulted in charges against 34 individuals and companies. Thirty-three individuals and companies settled the charges, accepted cease-and-desist orders and agreed to pay civil penalties ranging from $25,000 to $150,000.