Legal Proceedings
−Removed: From time to time, we may be subject to legal proceedings and claims in the ordinary course of business.
−Removed: We are not presently a party to any legal proceedings that are expected to have a material adverse impact on our financial position, results of operations or cash flows, nor have we been to date since inception.
−Removed: Wilson-Davis is not a party to any material legal proceedings, and no material legal proceedings have been threatened by Wilson-Davis or, to the best of its knowledge, against it, except that in December 2016, FINRA filed a complaint (FINRA Enforcement Matter No.
−Removed: 20120327318) asserting potential violations of several securities laws and regulations.
−Removed: Wilson-Davis denied the allegations and the hearing was held in November 2017.
−Removed: The FINRA panel issued its decision against Wilson-Davis in February 2018.
−Removed: Wilson-Davis was fined $1,170,000 and ordered to disgorge $51,624 for purported improper short sales.
−Removed: Wilson-Davis was fined an additional $300,000 for its purported failure to supervise and implement adequate AML procedures.
−Removed: Wilson-Davis filed a timely appeal.
−Removed: All sanctions were stayed while the appeal was pending before the FINRA National Adjudicatory Council (“NAC”).
−Removed: The appeal hearing before the NAC occurred in October 2018.
−Removed: On December 27, 2019, NAC issued a ruling that affirmed Wilson-Davis’ liability but reduced the sanctions imposed.
−Removed: Wilson-Davis was fined $350,000 and ordered to disgorge $51,624 for purported improper short sales.
−Removed: Wilson-Davis was fined an additional $750,000 for its purported failure to supervise and implement adequate AML procedures.
−Removed: Wilson-Davis timely appealed the ruling to the SEC.
−Removed: All sanctions are stayed while the appeal is pending before the SEC.
−Removed: The SEC has not made a ruling in this matter.
+Added: From time to time, we are subject to legal proceedings and claims in the ordinary course of business.Other than asdisclosed in Note 9, we are not presently a party to any legal proceedings that are expected to have a material adverse impact on our financial position, results of operations or cash flows.
+Added: See Note 9 for details regarding certain legal proceedings.
Mine Safety Disclosures
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Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.