On September 10, 2014, the U.S. Securities and Exchange Commission announced settlements with officers, directors, and significant shareholders for violating federal securities laws requiring information about their transactions in company stock. In addition, publicly-traded companies settled charges with the SEC for contributing to filing failures by insiders and failing to report their insiders’ filing delinquencies. Notable for its departure from the SEC’s previous practice of generally bringing such charges only in cases in which insiders were also being charged with other violations, these actions signal increased attention by the SEC on the compliance obligations of insiders and large shareholders of reporting companies. In addition, the actions send a strong message to insiders that any defenses they may rely upon regarding the untimely reporting of holdings or transactions in company stock may not be sufficient to prevent them from being subject to an action against them by the SEC and the imposition of a substantial monetary penalty.

SETTLEMENTS BY INSIDERS -

The SEC charged public company insiders with violations of the federal securities laws, specifically violations of Sections 16(a), 13(d) and 13(g) of the Securities Exchange Act of 1934, as amended (“Exchange Act”).