SEC Continues Enforcement Program Targeting Late Beneficial Ownership Reports

Following its adoption almost one year ago of amended rules accelerating filing deadlines for Schedules 13G and 13D (and the imminent effectiveness of the new deadlines for 13Gs), the SEC has continued to bring enforcement cases focusing on the timing of initial filings, amendments, and transitions from Schedule 13G to 13D, as well as Section 16 filings. The latest development is the SEC's announcement of settled enforcement cases against 23 persons, including investment firms and individual officers and directors for untimely filings, as well as two public companies for contributing to their insiders' violations and failing to disclose the delinquent filings as required. The penalties ranged from $10,000 to $200,000 for the individuals involved in the proceedings and from $40,000 to $750,000 for the entities involved. This follows a similar set of enforcement cases that the SEC announced in September of last year, as well as the SEC's recent set of actions targeting