In September, we wrote about the
SEC's enforcement actions against 23 investment firms for
violations of Rule 105 of Regulation M ("Rule 105") in an
effort to crack down on the potential manipulation of offering
prices of follow-on and secondary offerings. In the last two
months, the SEC has furthered Co-Director of Enforcement Andrew
Ceresney's promise to send a "clear message that
firms must pay the price for violations."
On Dec. 3, the SEC filed a complaint against Charles Raymond Langston III
for insider trading. In addition to the insider trading violations,
from which Langston made more than $193,108 in profits based upon
the receipt of material, nonpublic information, the commission also
charged Langston and two companies he owned and used to actively
trade securities ("Defendants") with three violations of
Rule 105.
