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In Release No.
44969 (Release) published on October 23, 2001, the United States Securities
and Exchange Commission (SEC) announces its decision to commence and settle a
cease-and-desist proceeding against Gisela de Leon-Meredith, former controller
of a subsidiary of a public company, Chestnut Hill Farms,
a Miami-based division of Seaboard Corporation. The SEC’s order found that Meredith caused the parent company’s
books and records to be inaccurate and its periodic reports misstated, and then
covered up those facts.
is significant because it sets forth some of the criteria the SEC will consider
in determining whether, and how much, to reward self-policing, self-reporting,
remediation and cooperation – from the extraordinary step of taking no
enforcement action to bringing reduced charges, seeking lighter sanctions, or
including mitigating language in documents used to announce and resolve
enforcement actions. The criteria are as follows:
1. What is the
nature of the misconduct involved? Did it result from inadvertence, honest
mistake, simple negligence, reckless or deliberate indifference to indicia of
wrongful conduct, willful misconduct or unadorned venality? Were the company’s
2. How did the misconduct arise? Is it the result of pressure
placed on employees to achieve specific results, or a tone of lawlessness set
by those in control of the company? What compliance procedures were in place to
prevent the misconduct now uncovered? Why did those procedures fail to stop or
inhibit the wrongful conduct?
3. Where in the organization did the misconduct occur? How high
up in the chain of command was knowledge of, or participation in, the
misconduct? Did senior personnel participate in, or turn a blind eye toward,
obvious indicia of misconduct? How systemic was the behavior? Is it symptomatic
of the way the entity does business, or was it isolated?
4. How long did the misconduct last? Was it a one-quarter, or
one-time, event, or did it last several years? In the case of a public company,
did the misconduct occur before the company went public? Did it facilitate the
company’s ability to go public?
5. How much harm has the misconduct inflicted upon investors and
other corporate constituencies? Did the share price of the company’s stock drop
significantly upon its discovery and disclosure?
6. How was the misconduct detected and who uncovered it?
7. How long after discovery of the misconduct did it take to
implement an effective response?
8. What steps did the company take upon learning of the
misconduct? Did the company immediately stop the misconduct? Are persons
responsible for any misconduct still with the company? If so, are they still in
the same positions? Did the company promptly, completely and effectively
disclose the existence of the misconduct to the public, to regulators and to
self-regulators? Did the company cooperate completely with appropriate
regulatory and law enforcement bodies? Did the company identify what additional
related misconduct is likely to have occurred? Did the company take steps to
identify the extent of damage to investors and other corporate constituencies?
Did the company appropriately recompense those adversely affected by the
9. What processes did the company follow to resolve many of these
issues and ferret out necessary information? Were the Audit Committee and the
Board of Directors fully informed? If so, when?
10. Did the company commit to learn the truth, fully and
expeditiously? Did it do a thorough review of the nature, extent, origins and
consequences of the conduct and related behavior? Did management, the Board or
committees consisting solely of outside directors oversee the review? Did
company employees or outside persons perform the review? If outside persons,
had they done other work for the company? Where the review was conducted by
outside counsel, had management previously engaged such counsel? Were scope
limitations placed on the review? If so, what were they?
11. Did the company promptly make available to SEC staff the results
of its review and provide sufficient documentation reflecting its response to
the situation? Did the company identify possible violative conduct and evidence
with sufficient precision to facilitate prompt enforcement actions against
those who violated the law? Did the company produce a thorough and probing
written report detailing the findings of its review? Did the company
voluntarily disclose information SEC staff did not directly request and
otherwise might not have uncovered? Did the company ask its employees to
cooperate with SEC staff and make all reasonable efforts to secure such
12. What assurances are there that the conduct is unlikely to
recur? Did the company adopt and ensure enforcement of new and more effective
internal controls and procedures designed to prevent a recurrence of the
misconduct? Did the company provide SEC staff with sufficient information for
it to evaluate the company’s measures to correct the situation and ensure that
the conduct does not recur?
13. Is the company the same company in which the misconduct
occurred, or has it changed through a merger or bankruptcy reorganization?
Please email me with
questions or leave a comment below!
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