The SEC announced its settlement of charges with more than 20 individuals and entities for failures to timely file beneficial ownership and insider transaction reports, including two public companies that failed to disclose Section 16 reporting delinquencies by their insiders in their proxy statements (here and here). We reported on a similar enforcement effort and associated guidance to companies via this Sullivan & Cromwell memo in September 2023 here (“SEC Cracks Down on Late Section 16 and 13 Filings”).
Adherence to updated beneficial ownership reporting rules was among the disclosure priorities noted by SEC Division of Corporation Finance Director Erik Gerding in a statement released in June 2024.