Pollack Center for Law & Business

SEED - SEC Enforcement Actions Database

Methodology

The SEED team maintains a database of SEC administrative proceedings and civil actions filed against public companies traded on major U.S. exchanges and their subsidiaries, excluding those actions that contain only delinquent filing allegations.  The SEED team is working to expand the database to include information for other types of defendants.  The team collects information only from publicly-available documents released by the SEC.  Each SEC enforcement-related document is analyzed by the SEED team and information on characteristics of each enforcement action is recorded.  The action enforcement characteristics collected and currently made available for the public in SEED include Defendant Name, Legal Case Name, District Court, Case Number or File Number, Allegation Type, Alleged Violations, Resolution Date, and Total Penalty and Disgorgement.    

Allegation Type: Each enforcement action is assigned a category describing the SEC’s primary allegation against the defendant. The allegation types presented are updated annually to be consistent with the SEC’s categorization of allegations in their public annual reports on statistics.

Alleged Violations: The specific statutory sections and rules the defendant is alleged to have violated.

Resolution Date: The date of the earliest document that mentions a resolution of the enforcement action.

Total Penalty and Disgorgement

  • If available, the Total Penalty and Disgorgement figure is taken directly from an SEC document as presented.
  • When Total Penalty and Disgorgement is not a reported figure, a sum is presented of the individual figures for Civil Penalty, Disgorgement, Prejudgment Interest, and Other Monetary Penalties. 
  • If more than one document for the same defendant in the same action contains a penalty or disgorgement amount, the data from the most recent document containing a penalty or disgorgement amount is shown.
  • Some penalties and disgorgement are shared with multiple defendants.  The database notes when a penalty or disgorgement is shared and reports the full shared penalty and disgorgement for each separate defendant without allocating the shared penalty and disgorgement among the defendants.