On September 27, 2023, the SEC announced a new “sweep” of enforcement actions against six insiders for failing to timely file multiple reports under Section 16 of the Securities Exchange Act of 1934 (Exchange Act) (and, for three of the insiders, also under Section 13 of the Exchange Act), and against five companies for negligence in contributing to their insiders’ reporting failures and/or for failing to properly disclose such reporting delinquencies in their annual proxy statement under Item 405 of Regulation S-K. The penalties associated with these actions against the insiders ranged from $120,000 to $150,000 and against the companies ranged from $115,000 to $200,000.
This sweep of actions is part of an ongoing enforcement initiative by the SEC that commenced in 2014 and demonstrates the SEC’s continued focus on enforcing Section 16 reporting requirements, particularly against repeated delinquent filers.
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