“Over the course of that day and the next, various BBPLC personnel attempted to calculate the cumulative amount of securities offered and sold from the 2019 Shelf in order to determine the amount of securities that remained available for sale. Over the course of these efforts, it became clear to all involved that there was no internal control in place to track in real time the amount of securities offered and sold against the amount of securities registered.”
I don’t think I’ve ever read a worse paragraph than that middle paragraph. I don’t think that you could write horror fiction scarier than that. This year for Halloween I am going to go as It Becoming Clear to All Involved That There Was No Internal Control in Place to Track in Real Time the Amount of Securities Offered and Sold Against the Amount of Securities Registered. I think I would rather be eaten by a werewolf than have that become clear to me.
That block quote is from an SEC order against Barclays, because last week Barclays settled with the SEC again, this time for selling unregistered securities. It registered $20.8 billion of securities, and overshot that by roughly $16.37 billion. Just not particularly close at all. It is illegal to sell unregistered securities, and so Barclays paid the SEC a $200 million fine.
‘Enforcement 40’ for 2020
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