Reprinted with the permission of The Legal Intelligencer.

On Sept. 10, the U.S. Securities and Exchange Commission (SEC) brought an unprecedented 28 charges against corporate insiders for a combined monetary penalty of $2.6 million for failure to timely file Section 16 and Section 13(d) and Section 13(g) reports. This so-called "enforcement sweep" suggests that the SEC has changed its approach to combating insider-trading violations and is, for the first time, using untimely filings of required disclosure reports as proxies for
insider-trading violations. In the past, the SEC used its resources to attack a few heavyweight offenders in the hopes of deterring insider trading through harsh sentences. By aiming for quantity over quality, the SEC has demonstrated a greater willingness to pursue suspected violations of varying degrees. ... 

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