Recent Articles & Comments

This is an instance of a violation where it seems inappropriate to impose a monetary penalty on the issuer (and indirectly on its shareholders), in which it did not benefit from the failure of disclosure. There is no suggestion in the SEC Order that the related party services were not actually rendered at value to the company. Therefore, this appears to be a pure disclosure case. The settlement underscores that it is important for companies to have some methodical system - perhaps a…