# Disclosure Insight® > Investment Research Focused on Public Company Interactions with the SEC. Public Ghost content for AI and LLM tooling. This file includes a bounded export of public pages first, then recent public posts. Append `.md` to any post or page URL to get the content in Markdown (for example, `/example-post.md`). ## Pages ### Welcome to Disclosure Insight! URL: https://www.disclosureinsight.com/about/ Last updated: 2026-09-30T20:41:09.000Z ***Published by John P. Gavin, CFA, NACD.DC*** Started in 2000, Disclosure Insight® (**DI**®) is an independent publisher of investment research that focuses on one thing, and one thing only: **Public company interactions with the US Securities and Exchange Commission (SEC).** **Our mission is simple**: DI helps investors at all levels assess the risk of an SEC interaction, disclosed or not, to help you achieve the returns you seek. Professionals such as auditors, insurance carriers, and attorneys who work with public companies also rely on our services to help them better serve their clients. It’s in our two taglines: ***Assess the Risk. Achieve the Return.®*** ***Better Disclosure for Better Decisions.®*** **DI research is heavily reliant on our ability to search and interpret company disclosures, paired with our expertise in using the Freedom of Information Act (FOIA).** - **DI is the only research provider who will consistently warn you of undisclosed SEC investigations.** At any given time, we typically track about 80 - 120 active-and-ongoing undisclosed SEC investigations of public companies. - **No one on Wall Street or in the private sector has the data and experience DI has** to help you identify, interpret, and assess the risk from SEC interactions with public companies. This is true whether they are disclosed or undisclosed. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/07/https-3a-2f-2fsubstack-post-media-s3-amazonaws-com-2fpublic-2fimages-2f044993a7-1be3-4a74-85fb-52d1800ef5a1_743x172-webp.jpg) #### **DI is owned and operated by a seasoned Wall Street securities analyst.** After putting myself through college, I got my start in the investment industry in 1985\. In 1992, I earned the **Chartered Financial Analyst** (CFA) credential. To keep expanding my knowledge, I recently received **Directorship Certification**® from the National Association of Corporate Directors (NACD.DC). **Outside of Wall Street**, I served for **20 years as a volunteer firefighter** and am still certified as a Nationally Registered **Emergency Medical Technician** (EMT). I was a command officer and, yes, did get to drive the big red trucks (which is super fun). With decades of training and experience across a wide array of roles, within and outside the industry, I’ve seen and done a lot. That experience informs the writing. ***From a front-page story the Wall Street Journal ran on me back in 2002:*** ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/07/https-3a-2f-2fsubstack-post-media-s3-amazonaws-com-2fpublic-2fimages-2f49e7a45f-2f1c-4a7b-b301-4e8aa88f13bb_774x311-png.jpg) - **Have you ever seen or used an SEC comment letter** in your research? If not, you should. These analytically-rich documents have been online at the SEC’s website for free since 2004, largely because of my early efforts using the FOIA. - In 2005, **I brought litigation against the SEC** for failure to comply with the FOIA. Fair to say, they know me well. - In 2010, I **received a patent** for an investment risk profiling methodology I invented. #### Looking forward to being of service. I am grateful to each of our readers and want to make it easy to engage with us. If you have questions after reviewing the FAQ’s (below), please don’t hesitate to email us at DIreports \[@\] disclosureinsight.com *\- John* ## Frequently Asked Questions #### **What Can Disclosure Insight Do for You?** An SEC investigation, whether it is disclosed or not, holds the potential to destabilize a company, distract its management, and/or interfere with underlying fundamentals. **Here’s how we help you assess this risk -** 1. **We alert you to public companies with undisclosed SEC investigations.** To do this, each year we file about 2,500 individual FOIA requests and hundreds of administrative appeals with the SEC. We take the FOIA replies, do in-depth and time-consuming research, and then publish our findings. Just the time savings alone from our work is highly valued by our subscribers. 2. **We help you interpret disclosed SEC investigative activity.** While not all SEC investigations are serious, many are. When companies do disclose an SEC investigation, few provide you enough information to analyze the risk they pose. We help you assess this risk. We closely examine the related disclosures and public statements made by the company. We then compare our findings to earlier research or documents we have in our library. #### **What Does it Cost?** - **For a limited time you can get Disclosure Insight research for free.** We have a well-established base of all-access consulting clients that keep the lights on as we grow our distribution. They get added services, such as analyst access, ability to make research requests, private calls & meetings, etc. - Those interested in learning more about becoming an all-access client, or to arrange enterprise-level access, email us at DIreports \[@\] disclosureinsight.com #### **What Do You Get as a Subscriber?** - **DI Watch List:** Published at the beginning of every month, this is our most widely read report. The DI Watch List shows and summarizes all companies on which our work found *undisclosed SEC investigation*s recently confirmed as active-and-ongoing. - **SEC Investigation Update Reports:** Published multiple times as needed each month, this report gives you updates and analysis on disclosed SEC investigations and those that are undisclosed, but recently confirmed as active-and-ongoing. - **Early Signals™ Reports:** Valued highly by the wide array of professionals we serve, Early Signals are your first indication of *POSSIBLE* SEC investigative activity at a company. Over the long-term, we found about 80% of these early signals are likely to be confirmed as having active-and-ongoing SEC investigations. - **DI Reports:** Published from time-to-time, these reports go in-depth regarding a problem we found at a company, or within a sector. #### **Who Will Benefit from Using our Service?** 1. **Professional investors**, both long and short. 2. **Individual investors** who manage their own portfolios. 3. **Attorneys**: The plaintiff’s bar, company counsel, and forensic investigators. 4. **Auditors**: Including their forensic investigation units. 5. **Insurance carriers**: Especially during the underwriting of Directors and Officers coverage. 6. **Boards of directors**, especially Audit Committees. 7. **Investor relations** professionals. 8. **Investigators:** Background search and other private investigators. 9. **Regulators:** Federal, state, and local law enforcement / regulators. ## Been at This a Long Time My hair is gray now, but I put these older images here to show you the long support and following I’ve enjoyed through the years. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/07/https-3a-2f-2fsubstack-post-media-s3-amazonaws-com-2fpublic-2fimages-2f3e989965-d97c-43d1-a90b-9cdc2751a5a9_1400x704-jpeg.jpg) ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/07/https-3a-2f-2fsubstack-post-media-s3-amazonaws-com-2fpublic-2fimages-2f4973b290-61bd-4926-8acb-529df6326790_624x516-webp.jpg) ### Legal / Terms of Service URL: https://www.disclosureinsight.com/tos/ Last updated: 2026-07-04T18:24:57.000Z ## **Legal / Terms of Service** DISCLAIMERS **Not an Investment Advisor** Disclosure Insight Inc. is not an investment advisor and does not offer or provide personalized investment advice. The information in any report published by Disclosure Insight or otherwise distributed is not a solicitation connected to any security nor recommendation that any particular security, portfolio of securities, transaction or investment strategy is suitable for any specific purpose or person. To the extent that any of the content published on DisclosureInsight.com may be understood as investment advice or recommendations in connection with a particular security, such information is impersonal and not tailored to the investment needs of any specific person. Disclosure Insight is not the solicitor and/or guarantor of any investment and cannot be held liable for any losses or expenses incurred as a result of reliance upon any information contained herein, and our work product, whether found at DisclosureInsight.com or elsewhere, is not a substitute for your own due diligence, which may include advice from an investment professional. The information we provide is obtained from company disclosures and our own Freedom of Information Act requests made to the Securities and Exchange Commission or elsewhere. No representation or warranty is made as to the accuracy, timeliness or completeness of any information found in our reports or on DisclosureInsight.com. All content in any report published by Disclosure Insight or otherwise distributed is presented only as of the date published or indicated, and may be superseded by subsequent market events or for other reasons, which may not be published. Disclosure Insight does not represent or warrant the truth or falsity of the contents of any of the documents or filings referred to within our reports or on this website, and no conclusion of wrongdoing should be inferred from the fact that an investigation has been initiated by the SEC. **Potential Conflicts of Interest** **Disclosure Insight does not take any security positions** except in connection with routine corporate treasury functions, or engage in investment banking activities. **Disclosure Insight prohibits its employees and principals from trading of any kind in any individual public company security (or derivative thereof) of any company about which a research report, blog entry, video, audio, or other publication has commenced.** This embargo on trading lasts for a minimum of 5 days after the investigation’s existence has been published, added to its database (even if not published) or its research on that issue otherwise ceases. Disclosure Insight otherwise permits its employees to freely trade in any securities so long as such trading is not deemed to be in conflict with this policy. Likewise, Disclosure Insight places no holding period limits or restrictions on such personal trading. This could, and often does, include trading in mutual funds, exchange traded funds (ETFs), and derivatives thereof that may include covered names as components of the overall funds and/or ETFs. In addition, Disclosure Insight requires its employees and principals to adhere to the CFA Institute Code of Ethics and Standards of Professional Conduct regarding potential conflicts of interest. This includes prohibiting its employees and principals from trading in their own accounts in any manner which might be deemed in conflict with its readers, whether paying subscribers or not. **Privately-Held Company** Disclosure Insight Inc. is a privately-held publisher of investment research that is not in any way affiliated with the U.S. Securities and Exchange Commission or any other branch or agency of government. It is 100% owned by John P. Gavin, CFA, NACD.DC. ## **TERMS OF SERVICE** AS A CONDITION TO YOUR USE OF THE DISCLOSURE INSIGHT WEB SITE, DISCLOSURE INSIGHT INC. (“Disclosure Insight” or “we”) REQUIRES THAT YOU REVIEW AND UNDERSTAND THE FOLLOWING TERMS OF SERVICE (the “TOS”). BY USING THE DISCLOSURE INSIGHT WEB SITE, YOU ACCEPT AND AGREE TO COMPLY WITH EACH AND EVERY TERM OF SERVICE SET FORTH BELOW. PLEASE READ OUR TERMS OF USE CAREFULLY BEFORE YOU USE OR REGISTER FOR ACCESS TO THE DISCLOSURE INSIGHT WEB SITE: **1\. Agreement Generally** By using this site, you consent and agree to the TOS. If you do not agree to the terms and conditions contained in the TOS you may not access or otherwise use DisclosureInsight.com or any information contained herein. You also affirm that you are over the age of 18. Users who register with DisclosureInsight.com will be assigned a User account. **User names, passwords, and/or access to our content are assigned to individuals and not organizations.** These User names and passwords, or any other means to access our content, may not be shared with anyone else, and when creating your User account, you must provide accurate and complete information, and you may only maintain a single account. You must notify us immediately of any breach of security or unauthorized use of your account. You may not modify, adapt, sublicense, translate, sell, reverse engineer, decompile or disassemble any portion of DisclosureInsight.com. You may not use any robot, spider, site search/retrieval application, artificial intelligence tools or other manual or automatic device or process to download, retrieve, index, “data mine,” “scrape” or in any way reproduce or circumvent the navigational structure or presentation of DisclosureInsight.com or its contents. You may not use DisclosureInsight.com for: any unlawful purpose; to harvest or aggregate information about visitors to DisclosureInsight.com without their express consent; to send unsolicited or unauthorized advertisements, spam, chain letters, etc. to other users of DisclosureInsight.com; or to transmit anything to DisclosureInsight.com which contains software viruses, or other harmful computer code, programs or files. • DISCLOSUREINSIGHT.COM PROVIDES TIMELY AND NEWSWORTHY INFORMATION COMPILED AT CONSIDERABLE EFFORT AND EXPENSE. IT IS A CONDITION OF THIS AGREEMENT THAT YOU MAY NOT USE CONTENT ON DISCLOSUREINSIGHT.COM OR IN DISCLOSUREINSIGHT.COM E-MAIL ALERTS TO PUBLISH, REDISTRIBUTE OR AGGREGATE THAT CONTENT. • YOU MAY REFER TO DISCLOSUREINSIGHT.COM IN SOCIAL MEDIA IF YOU INCLUDE A LINK TO DISCLOSUREINSIGHT.COM. • YOU MAY DUPLICATE OR COPY ONLY SMALL EXTRACTS AND/OR “CUT AND PASTE” PORTIONS OF THE CONTENT ON DISCLOSUREINSIGHT.COM IF YOU INCLUDE PROPER AND PROMINENT ATTRIBUTION AND, IF APPLICABLE, A LINK TO DISCLOSUREINSIGHT.COM. **2\. Changes to the TOS and Cancellation** We reserve the right with sole discretion at any time to: Change the terms and conditions of the TOS; change the design of DisclosureInsight.com; to cancel any Authorized User’s access for violations of the TOS for system maintenance or security reasons, or to comply with any legal requirements in Disclosure Insight Inc.’s interest. **3\. Intellectual Property: Trademarks and Copyright** Disclosure Insight® and the Disclosure Insight logo; Probes Reporter®; They Know it. Now You Know It.®; Better Disclosure for Better Decisions®; Assess the Risk. Achieve the Return®; DI® ; Early Signals™;and, Disclosure Games®, are trademarks of Probes Reporter, LLC and are proprietary. You may not use these trademarks in any manner that can be construed as endorsement by or association with Disclosure Insight Inc. and/or Probes Reporter, LLC. **You may access and use any content found on DisclosureInsight.com and download and/or print out copies of any content from DisclosureInsight.com solely for your personal, non-commercial use.** If you download or print a copy of the content for personal use, you must retain all copyright and other proprietary notices contained therein. You acknowledge that you do not acquire any ownership rights by using content from DisclosureInsight.com. You may not copy and/or “cut-and-paste” content found on DisclosureInsight.com for the purpose of redistribution to other persons or entities, in any form except with prior written authorization of Disclosure Insight Inc. or as otherwise expressly permitted in the TOS. **4\. Your Privacy** Click here to view the Disclosure Insight Privacy Policy. **COPYRIGHT ABUSE** Disclosure Insight Inc. makes best efforts to assure that copyrighted material does not appear on our website. Disclosure Insight Inc. cannot be held liable for any losses or damages under a theory of contributory infringement as a result of any such postings appearing on DisclosureInsight.com. If you believe that any material available on DisclosureInsight.com infringes on your copyright(s), please notify us by providing notice complying with the [Digital Millennium Copyright Act](https://www.copyright.gov/dmca/?ref=disclosureinsight.com) (DMCA - link is external). Upon receipt of a complete and valid notice, we will remove the material and make a good faith attempt to contact the user who uploaded or embedded the material by email. DMCA notices should be directed by mail and/or overnight courier service to: Nathan E. Ray, Esq., Fabyanske Westra Hart & Thomson, P.A. 80 South Eighth Street Suite 1900 Minneapolis, MN 55402 Tel: 612-359-7600 **OUR PROPRIETARY INTERESTS** The works of authorship contained in any material published by Disclosure Insight Inc. or otherwise distributed, including but not limited to all data, design, text, images, charts and other data compilations or collective works, are owned by Disclosure Insight Inc. or one of its affiliates and may not be copied, reproduced, transmitted, displayed, performed, distributed, rented, sublicensed, altered, or stored for subsequent use, in whole or in part in any manner, without the prior written consent of Disclosure Insight Inc. Photocopying or electronic distribution without the prior written consent of Disclosure Insight Inc. violates U.S. copyright law, and may be punishable by statutory damages of up to $150,000 per infringement, plus attorneys’ fees (17 USC 504 et. seq.). Without advance written permission, illegal copying includes regular photocopying, faxing, excerpting, forwarding electronically and sharing of online access. With the exception of: 1) underlying filings made by companies to the Securities and Exchange Commission; and 2) Freedom of Information responses issued by the Securities and Exchange Commission, all content, including but not limited to selection and arrangement, analysis, reporting, collection, graphic material such as charts and graphs, and the look and feel of content available from DisclosureInsight.com, as well as the timeliness of such content, is wholly proprietary, has a vested commercial value, and is subject to copyright law and the doctrine of “hot news misappropriation.” Infringement of these laws may result in civil and criminal liability under common-law doctrines including without limitation interference with prospective business advantage and tortious interference with contract, and in cases of willful infringement, an award of attorney’s fees. The obligations contained in this section shall survive in perpetuity. **CONTACT US** Disclosure Insight Inc., P.O. Box 47331, Plymouth, MN 55447 direports \[at\] disclosureinsight.com ## DISCLAIMERS **Not an Investment Advisor** Disclosure Insight Inc. is not an investment advisor and does not offer or provide personalized investment advice. The information in any report published by Disclosure Insight or otherwise distributed is not a solicitation connected to any security nor recommendation that any particular security, portfolio of securities, transaction or investment strategy is suitable for any specific purpose or person. To the extent that any of the content published on DisclosureInsight.com may be understood as investment advice or recommendations in connection with a particular security, such information is impersonal and not tailored to the investment needs of any specific person. Disclosure Insight is not the solicitor and/or guarantor of any investment and cannot be held liable for any losses or expenses incurred as a result of reliance upon any information contained herein, and our work product, whether found at DisclosureInsight.com or elsewhere, is not a substitute for your own due diligence, which may include advice from an investment professional. The information we provide is obtained from company disclosures and our own Freedom of Information Act requests made to the Securities and Exchange Commission or elsewhere. No representation or warranty is made as to the accuracy, timeliness or completeness of any information found in our reports or on DisclosureInsight.com. All content in any report published by Disclosure Insight or otherwise distributed is presented only as of the date published or indicated, and may be superseded by subsequent market events or for other reasons, which may not be published. Disclosure Insight does not represent or warrant the truth or falsity of the contents of any of the documents or filings referred to within our reports or on this website, and no conclusion of wrongdoing should be inferred from the fact that an investigation has been initiated by the SEC. **Potential Conflicts of Interest** **Disclosure Insight does not take any security positions** except in connection with routine corporate treasury functions, or engage in investment banking activities. **Disclosure Insight prohibits its employees and principals from trading of any kind in any individual public company security (or derivative thereof) of any company about which a research report, blog entry, video, audio, or other publication has commenced.** This embargo on trading lasts for a minimum of 5 days after the investigation’s existence has been published, added to its database (even if not published) or its research on that issue otherwise ceases. Disclosure Insight otherwise permits its employees to freely trade in any securities so long as such trading is not deemed to be in conflict with this policy. Likewise, Disclosure Insight places no holding period limits or restrictions on such personal trading. This could, and often does, include trading in mutual funds, exchange traded funds (ETFs), and derivatives thereof that may include covered names as components of the overall funds and/or ETFs. In addition, Disclosure Insight requires its employees and principals to adhere to the CFA Institute Code of Ethics and Standards of Professional Conduct regarding potential conflicts of interest. This includes prohibiting its employees and principals from trading in their own accounts in any manner which might be deemed in conflict with its readers, whether paying subscribers or not. **Privately-Held Company** Disclosure Insight Inc. is a privately-held publisher of investment research that is not in any way affiliated with the U.S. Securities and Exchange Commission or any other branch or agency of government. It is 100% owned by John P. Gavin, CFA, NACD.DC. ## **TERMS OF SERVICE** AS A CONDITION TO YOUR USE OF THE DISCLOSURE INSIGHT WEB SITE, DISCLOSURE INSIGHT INC. (“Disclosure Insight” or “we”) REQUIRES THAT YOU REVIEW AND UNDERSTAND THE FOLLOWING TERMS OF SERVICE (the “TOS”). BY USING THE DISCLOSURE INSIGHT WEB SITE, YOU ACCEPT AND AGREE TO COMPLY WITH EACH AND EVERY TERM OF SERVICE SET FORTH BELOW. PLEASE READ OUR TERMS OF USE CAREFULLY BEFORE YOU USE OR REGISTER FOR ACCESS TO THE DISCLOSURE INSIGHT WEB SITE: **1\. Agreement Generally** By using this site, you consent and agree to the TOS. If you do not agree to the terms and conditions contained in the TOS you may not access or otherwise use DisclosureInsight.com or any information contained herein. You also affirm that you are over the age of 18. Users who register with DisclosureInsight.com will be assigned a User account. **User names, passwords, and/or access to our content are assigned to individuals and not organizations.** These User names and passwords, or any other means to access our content, may not be shared with anyone else, and when creating your User account, you must provide accurate and complete information, and you may only maintain a single account. You must notify us immediately of any breach of security or unauthorized use of your account. You may not modify, adapt, sublicense, translate, sell, reverse engineer, decompile or disassemble any portion of DisclosureInsight.com. You may not use any robot, spider, site search/retrieval application, artificial intelligence tools or other manual or automatic device or process to download, retrieve, index, “data mine,” “scrape” or in any way reproduce or circumvent the navigational structure or presentation of DisclosureInsight.com or its contents. You may not use DisclosureInsight.com for: any unlawful purpose; to harvest or aggregate information about visitors to DisclosureInsight.com without their express consent; to send unsolicited or unauthorized advertisements, spam, chain letters, etc. to other users of DisclosureInsight.com; or to transmit anything to DisclosureInsight.com which contains software viruses, or other harmful computer code, programs or files. • DISCLOSUREINSIGHT.COM PROVIDES TIMELY AND NEWSWORTHY INFORMATION COMPILED AT CONSIDERABLE EFFORT AND EXPENSE. IT IS A CONDITION OF THIS AGREEMENT THAT YOU MAY NOT USE CONTENT ON DISCLOSUREINSIGHT.COM OR IN DISCLOSUREINSIGHT.COM E-MAIL ALERTS TO PUBLISH, REDISTRIBUTE OR AGGREGATE THAT CONTENT. • YOU MAY REFER TO DISCLOSUREINSIGHT.COM IN SOCIAL MEDIA IF YOU INCLUDE A LINK TO DISCLOSUREINSIGHT.COM. • YOU MAY DUPLICATE OR COPY ONLY SMALL EXTRACTS AND/OR “CUT AND PASTE” PORTIONS OF THE CONTENT ON DISCLOSUREINSIGHT.COM IF YOU INCLUDE PROPER AND PROMINENT ATTRIBUTION AND, IF APPLICABLE, A LINK TO DISCLOSUREINSIGHT.COM. **2\. Changes to the TOS and Cancellation** We reserve the right with sole discretion at any time to: Change the terms and conditions of the TOS; change the design of DisclosureInsight.com; to cancel any Authorized User’s access for violations of the TOS for system maintenance or security reasons, or to comply with any legal requirements in Disclosure Insight Inc.’s interest. **3\. Intellectual Property: Trademarks and Copyright** Disclosure Insight® and the Disclosure Insight logo; Probes Reporter®; They Know it. Now You Know It.®; Better Disclosure for Better Decisions®; Assess the Risk. Achieve the Return®; DI® ; Early Signals™;and, Disclosure Games®, are trademarks of Probes Reporter, LLC and are proprietary. You may not use these trademarks in any manner that can be construed as endorsement by or association with Disclosure Insight Inc. and/or Probes Reporter, LLC. **You may access and use any content found on DisclosureInsight.com and download and/or print out copies of any content from DisclosureInsight.com solely for your personal, non-commercial use.** If you download or print a copy of the content for personal use, you must retain all copyright and other proprietary notices contained therein. You acknowledge that you do not acquire any ownership rights by using content from DisclosureInsight.com. You may not copy and/or “cut-and-paste” content found on DisclosureInsight.com for the purpose of redistribution to other persons or entities, in any form except with prior written authorization of Disclosure Insight Inc. or as otherwise expressly permitted in the TOS. **4\. Your Privacy** Click here to view the Disclosure Insight Privacy Policy. **COPYRIGHT ABUSE** Disclosure Insight Inc. makes best efforts to assure that copyrighted material does not appear on our website. Disclosure Insight Inc. cannot be held liable for any losses or damages under a theory of contributory infringement as a result of any such postings appearing on DisclosureInsight.com. If you believe that any material available on DisclosureInsight.com infringes on your copyright(s), please notify us by providing notice complying with the [Digital Millennium Copyright Act](https://www.copyright.gov/dmca/?ref=disclosureinsight.com) (DMCA - link is external). Upon receipt of a complete and valid notice, we will remove the material and make a good faith attempt to contact the user who uploaded or embedded the material by email. DMCA notices should be directed by mail and/or overnight courier service to: Nathan E. Ray, Esq., Fabyanske Westra Hart & Thomson, P.A. 80 South Eighth Street Suite 1900 Minneapolis, MN 55402 Tel: 612-359-7600 **OUR PROPRIETARY INTERESTS** The works of authorship contained in any material published by Disclosure Insight Inc. or otherwise distributed, including but not limited to all data, design, text, images, charts and other data compilations or collective works, are owned by Disclosure Insight Inc. or one of its affiliates and may not be copied, reproduced, transmitted, displayed, performed, distributed, rented, sublicensed, altered, or stored for subsequent use, in whole or in part in any manner, without the prior written consent of Disclosure Insight Inc. Photocopying or electronic distribution without the prior written consent of Disclosure Insight Inc. violates U.S. copyright law, and may be punishable by statutory damages of up to $150,000 per infringement, plus attorneys’ fees (17 USC 504 et. seq.). Without advance written permission, illegal copying includes regular photocopying, faxing, excerpting, forwarding electronically and sharing of online access. With the exception of: 1) underlying filings made by companies to the Securities and Exchange Commission; and 2) Freedom of Information responses issued by the Securities and Exchange Commission, all content, including but not limited to selection and arrangement, analysis, reporting, collection, graphic material such as charts and graphs, and the look and feel of content available from DisclosureInsight.com, as well as the timeliness of such content, is wholly proprietary, has a vested commercial value, and is subject to copyright law and the doctrine of “hot news misappropriation.” Infringement of these laws may result in civil and criminal liability under common-law doctrines including without limitation interference with prospective business advantage and tortious interference with contract, and in cases of willful infringement, an award of attorney’s fees. The obligations contained in this section shall survive in perpetuity. **CONTACT US** Disclosure Insight Inc., P.O. Box 47331, Plymouth, MN 55447 direports \[at\] disclosureinsight.com ### Privacy Policy URL: https://www.disclosureinsight.com/privacy/ Last updated: 2026-08-19T17:20:12.000Z **Effective date: February 8, 2025** Disclosure Insight, Inc. (“Disclosure Insight”, “DI”, “us”, “we”, or “our”) operates the DISCLOSUREINSIGHT.COM website (the “Service”). We are strongly committed to protecting your privacy online and have taken steps to protect the information you share with us. Disclosure Insight collects certain personal information to provide \\you with customized services and content. This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. ## **Definitions** ### **Personal Data** Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession). ### **Usage Data** Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit). ### **Cookies** Cookies are small pieces of data stored on a User’s device. ### **Data Controller** Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data. ### **Data Processor (or Third-Party Service Providers)** Data Processor (or Third-Party Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller. We use the services of various Third-Party Service Providers to process your data more effectively and to provide you with a better shopping experience. ### **Data Subject** Data Subject is any living individual who is the subject of Personal Data. ### **User** The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data. ## **Information Collection and Use** We collect several different types of information for various purposes to provide and improve our Service to you. ### **Types of Data Collected** #### *Personal Data* While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to: - Email address - First name and last name - Physical Address - Usage Data We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. **You may opt out of receiving any, or all, of these communications from us by contacting us at privacy \[at\] disclosureinsight.com.** #### *Usage Data* We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. #### *Tracking Cookies Data and Web Beacons* Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. We also use “web beacons” which are single pixel gifs, in our emails. ## **Use of Data** Disclosure Insight uses the data for various purposes: - To provide and maintain our Service - To notify you about changes to our Service - To allow you to participate in interactive features of our Service when you choose to do so - To provide customer support - To gather analysis or valuable information so that we can improve our Service - To monitor the usage of our Service - To detect, prevent and address technical issues - To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information ## **Retention of Data** Disclosure Insight will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. 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Some of our reports will still be free, but not all of them. > A limited number of new All‑Access institutional engagements will be reserved for those who need direct analyst access. > > This access is on a highly selective basis. If interested, contact us to further discuss. ### SEC Investigation Updates: September 30, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-september-30-2026/ Last updated: 2026-09-30T14:34:19.000Z ### *Click the PDF below to access today’s report* [SEC Investigation Updates: September 30, 2026Updates on SEC investigative activity - Nine (9) companies in today’s report.SIU Report - FS - 2026-0930.pdf1 MBdownload-circle](https://www.disclosureinsight.com/content/files/2026/09/SIU-Report---FS---2026-0930.pdf "Download") [Subscribe now](#/portal/signup) ### Service Note: Disclosure Insight will soon have a paywall The paywall is being put back into place to preserve value for people who want real-time access to all DI research reports. 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Some of our reports will still be free, but not all of them. > A limited number of new All‑Access institutional engagements will be reserved for those who need direct analyst access. > > This access is on a highly selective basis. If interested, contact us to further discuss. ### DI's Early Signals Report: September 09, 2026 URL: https://www.disclosureinsight.com/dis-early-signals-report-september-09-2026/ Last updated: 2026-09-09T00:52:06.000Z ### [Read Full Early Signals Report Here](https://www.disclosureinsight.com/content/files/2026/09/DI-Early-Signals---FS---2026-0909-1.pdf) #### [Subscribe now](#/portal/signup) ### Service Note: Disclosure Insight will soon have a paywall For readers who want priority access to all DI research reports going forward. The period of free access will soon end. > A limited number of new All‑Access institutional engagements will be reserved for those who need direct analyst access. > > This access is on a highly selective basis. 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The link in our last email took you to the wrong report.* ### [*Read full SEC Investigation Update Report here*](https://www.disclosureinsight.com/content/files/2026/08/SIU-Report---FS---2026-0831-1.pdf) [Subscribe now](#/portal/signup) ## Companies in Today's Report Amazon .com, Inc. – AMZN America Movil S.A.B. de C.V. – AMX Broadcom, Inc. – AVGO C3 .ai, Inc. – AI Check Point Software Technologies Ltd. – CHKP F5, Inc. – FFIV Gamestop Corp. – GME Granite Point Mortgage Trust, Inc. – GPMT Hub Group, Inc. – HUBG Microsoft Corp. – MSFT NASDAQ, Inc. – NDAQ Trade Desk, Inc. – TTD Victoria’s Secret & Co. – VSXY ### Service Note: Disclosure Insight will soon have a paywall For readers who want priority access to all DI research reports going forward. The period of free access will soon end. > A limited number of new All‑Access institutional engagements will be reserved for those who need direct analyst access. > > This access is on a highly selective basis. If interested, contact us to further discuss. ### SEC Investigation Updates: August 31, 2026 (re-send) URL: https://www.disclosureinsight.com/sec-investigation-updates-august-31-2026-re-send/ Last updated: 2026-08-31T02:42:40.000Z *This is a re-send. The link in our last email took you to the wrong report.* ### [*Read full SEC Investigation Update Report here*](https://www.disclosureinsight.com/content/files/2026/08/SIU-Report---FS---2026-0831-1.pdf) [Subscribe now](#/portal/signup) ## Companies in Today's Report Amazon .com, Inc. – AMZN America Movil S.A.B. de C.V. – AMX Broadcom, Inc. – AVGO C3 .ai, Inc. – AI Check Point Software Technologies Ltd. – CHKP F5, Inc. – FFIV Gamestop Corp. – GME Granite Point Mortgage Trust, Inc. – GPMT Hub Group, Inc. – HUBG Microsoft Corp. – MSFT NASDAQ, Inc. – NDAQ Trade Desk, Inc. – TTD Victoria’s Secret & Co. – VSXY ### Service Note: Disclosure Insight will soon have a paywall For readers who want priority access to all DI research reports going forward. The period of free access will soon end. > A limited number of new All‑Access institutional engagements will be reserved for those who need direct analyst access. > > This access is on a highly selective basis. If interested, contact us to further discuss. ### SEC Investigation Updates - August 27, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-august-27-2026/ Last updated: 2026-09-24T00:57:52.000Z ### [*Read full SEC Investigation Update Report here*](https://www.disclosureinsight.com/content/files/2026/08/SIU-Report---NF---2026-0827.pdf) [Subscribe](#/portal/signup) > **Service Note: Disclosure Insight will soon have a paywall for those readers who want priority access to all DI research reports going forward.** The period of free access to most of our research work will soon end. > A limited number of new All‑Access institutional engagements will be reserved for those who need direct analyst access. This access is on a highly selective basis. If interested, contact us to further discuss. ### CrowdStrike: Can You Trust the Annual Recurring Revenue Numbers? URL: https://www.disclosureinsight.com/crowdstrike-can-you-trust-the-annual-recurring-revenue-numbers/ Last updated: 2026-08-24T17:10:33.000Z **CrowdStrike Holdings, Inc. – CRWD $191.95 US Mkt Cap: $** **195.5 B** [***Click here***](https://www.disclosureinsight.com/content/files/2026/08/DI-Alert---CrowdStrike-Holdings---CRWD-2026-0823-2.pdf) *a PDF version of today's report* ## Summary and Opinion: With the stock of CrowdStrike up over 100% since spring, the Street’s been giddy with delight over reported growth in Annual Recurring Revenue (ARR) – now one of the central pillars of the CrowdStrike investment narrative. Non-believers are few. We are one of them. In our opinion, the Disclosure Games we cite here, along with governance concerns we found involving the Audit Committee, suggest you cannot trust the ARR story without closer scrutiny. Let’s have a look. Through clever wordsmithing and use of a term most investors never use day-to-day (**“recognition of revenue”** versus **revenue recognition**), we contend CrowdStrike was successful in keeping investors from focusing on what we view as serious SEC/DOJ accounting investigations. They involve CrowdStrike’s revenue recognition “and reporting of ARR for transactions with certain customers.” **In today’s report we also identify and speak to concerns about the Audit Committee**, with focus on the following: - CrowdStrike’s otherwise highly qualified Audit Chair has so many commitments outside of this one that it appears she is spread too thin. The audit committee chair is one of the most demanding roles on any public company board. A company facing dual SEC/DOJ accounting investigations places even more time demands on top of this. We will show you the robust portfolio of board roles this Chair has outside of CrowdStrike, letting you decide for yourself. - The company Chairman sits on the Audit Committee. We explain why this is less-than-ideal for good governance, especially with ongoing SEC/DOJ probes. - We found a recent and quiet departure of an Audit Committee member who was in the role since 2017\. He was not replaced on the board. Total board size is now reduced, from 9 to 8 current members. Later, we will show you where we believe CrowdStrike played – and keeps playing its Disclosure Games around its SEC/DOJ investigations. We argue these games had the effect of lulling investors into a false sense of confidence in the integrity of reported ARR numbers at CrowdStrike. At minimum, ARR requires further vetting. ### The Current SEC Enforcement Environment Before we get further into it, now is a good time to remind you that we are in an environment where the SEC is investigating far fewer companies than was the case when Trump came back into office. CrowdStrike’s investigations involve serious accounting matters. Our work suggests the SEC piece has been ongoing for at least 18 months, since Jan-2025\. There is potential criminal exposure as well. This should drive home the urgency of finding out what’s really going on regarding these risks at CrowdStrike. ### From DI Research - DI’s Early Signal of SEC probe: 17-Jan-2025 - SEC probe confirmed as ongoing: 24-Apr-2025 - First disclosure of SEC probe: 04-Jun-2025 In Jun-2026, the SEC again confirmed investigative activity remained active and ongoing at CrowdStrike. ### The Dual SEC/DOJ Investigations Even though they never used these words, in Jun-2025, CrowdStrike made its first disclosure of what we recognize as SEC/DOJ investigations into revenue recognition and reporting of Annual Recurring Revenue (ARR). As you can see above, we first knew of an undisclosed SEC probe at CrowdStrike months earlier, in Jan-2025. Without change or update, CrowdStrike has repeated the following in every major filing since first disclosed in Jun-2025, most recently in the 10-Q filed on 04-Jun-2026. **From the CrowdStrike 10-Q filed on 04-Jun-2025:** > The Company has received **requests for information** from the U.S. Department of Justice and the U.S. Securities and Exchange Commission relating to the Company’s **recognition of revenue** and reporting of ARR for transactions with **certain customers**, the July 19 Incident and related matters. The Company is cooperating and providing information in response to these requests. Given how these matters usually run, we suspect this exposure is now a formal SEC investigation paired with possible criminal exposure at the DOJ. ### Words Matter The wording here deserves particular attention. We find it to be manipulative and evasive. Sleazy even. This matters because it appears the CrowdStrike stock price is increasingly driven by ARR acceleration. We also found the wording especially creative. We cannot recall having ever heard a company refer to an SEC investigation into revenue recognition expressed as “recognition of revenue,” as was done here. Consider this: Even with our sophisticated search strings and decades of going through SEC filings, we almost missed this. This was quite the evasive disclosure. Have you seen analyst reports or conference calls talk about SEC/DOJ investigations into CrowdStrike’s revenue recognition and reporting of ARR for transactions with unidentified customers? If not, can you have confidence this risk has been assessed and discounted by investors? We contend it has not. The Audit Committee was responsible for reviewing the company’s financial disclosures, including this regulatory matter involving revenue recognition and ARR. The company’s use of the terms, “requests for information” and “recognition of revenue” is … well, it’s notable. Later we will detail the Disclosure Games we found here. Let’s have a closer look at the Audit Committee first. [Subscribe now](#/portal/signup) ### **Gov**ernance / Audit C**ommittee Concerns** > *The oversight responsibility of boards and directors has become increasingly complex amid changes to the political, geopolitical, and economic environment that are expanding the board agenda … Boards face these challenges with the finite resource of director time.* > *… *annual independent director time commitment has increased from less than 250 hours to more than 300 hours over the last decade.* However, there are practical limits to how much this time commitment can increase without generating questions about director independence.* \[emphasis added\] Source: National Association of Corporate Directors, [***2025 Inside the Public Company Boardroom***](https://prod.nacdonline.org/all-governance/governance-resources/governance-surveys/surveys-benchmarking/2025-inside-the-public-company-boardroom/?utm%5Fsource=chatgpt.com), April 01, 2025. ### CrowdStrike’s highly qualified Audit Chair may be spread too thin. Roxanne Austin has chaired CrowdStrike’s Audit Committee since 2018\. Her financial background is impressive, with various audit positions early, at Deloitte & Touche from 1983-1993, including Audit Partner. Her reputation in the governance community is stellar. Talent like Ms. Austin is highly sought after on public company boards. A fair concern, though, is that her current commitments both at, and outside of CrowdStrike are substantial. Quite substantial. Here we point to the following and ongoing commitments of Ms. Austin, none of which are light engagements – - **Austin Investment Advisors**, President and CEO, **Public company boards on which Ms. Austin serves:** - **CrowdStrike Holdings (CRWD)**: Audit Committee Chair **Verizon Communications (VZ):** Audit Committee Chair **AbbVie, Inc. (ABBV)**: Lead Independent Director **Freshworks, Inc. (FRSH):** Board Chair, Nominating & Governance Chair This is not just a busy executive – this is an extraordinarily busy one. When the issue is a potentially serious SEC/DOJ matter involving revenue recognition and ARR reporting, bandwidth of your audit chair becomes a legitimate governance concern. In governance circles the audit committee chair is seen as one of the most demanding roles on any public company board. Ms. Austin chairs the audit committees of two large public companies – Verizon and CrowdStrike; the latter demanding even more time due to its SEC/DOJ scrutiny. Ms. Austin is also Lead Independent Director at AbbVie, another large public company. That alone is a sizable time commitment. The cherry on this sundae is she’s also the Board Chair at Freshworks. ### The independent Chairman of CrowdStrike also sits on its Audit Committee. CrowdStrike’s Chairman of the Board, Gerhard Watzinger, is also one of only three members on its Audit Committee. There is nothing technically wrong with that. But CrowdStrike could readily recruit qualified, independent talent to its Audit Committee. Instead, the Board Chair occupies one of just three seats on the committee responsible for independently challenging management on sensitive financial reporting and disclosure matters. This includes those disclosures we’ve criticized concerning the SEC/DOJ investigations. ### A longtime Audit Committee member recently and quietly departed. Godfrey R. Sullivan, age 72, served on CrowdStrike’s board and Audit Committee since Dec-2017\. Sullivan was a Class I director, whose seat came up for renewal in 2026 along with those of Johanna Flower and Denis O’Leary. This is where things get interesting. The Nominating & Corporate Governance Committee renominated Flower and O’Leary, but not Sullivan. Absent the nomination, his term expired following the 17-Jun-2026 annual meeting. This reduced the board from nine directors to eight. Director Cary Davis subsequently joined the Audit Committee. Why was Sullivan not renominated, and why was there no contemporaneous explanation for the departure of a long-serving Audit Committee member? [Subscribe now](#/portal/signup) ### CrowdStrike’s Disclosure Games > *“*Disclosure Games®*” is a term we use to highlight those public companies engaging in disclosure practices that in our opinion may be misleading, confusing, evasive, or otherwise lacking the transparency needed for investors to make well-informed investment decisions regarding a potentially material exposure. *For reasons outlined in this report, we have identified CrowdStrike as a company playing Disclosure Games.** We now examine the Disclosure Games we assert CrowdStrike played regarding its SEC/DOJ investigations involving one of the most widely followed metrics of the company. ### Disclosure Game #1 ***“The Company has received requests for information”*** Note the absence of the words investors commonly recognize as indicative of a company disclosing an investigation, such as inquiry, probe, investigation, formal, informal, or subpoena. Instead of telling you they were under investigation by the SEC and DOJ, CrowdStrike gave us the more soothing expression, “The Company has received requests for information.” We’ve seen this game before. It’s evasive. **Here’s what’s missing from this disclosure today:** - When were the first “requests for information”? When did you last receive a “request for information”? What information has been requested? Who requested it? Were subpoenas involved? Have there been more requests over time? Have the matters at issue expanded? ### Disclosure Game #2: ***“recognition of revenue and reporting of ARR for transactions with certain customers”*** Every accountant, every analyst, routinely uses the term, “revenue recognition.” CrowdStrike itself says revenue recognition throughout their filings. Yet here, just once in each filing in which it appears, when the company is telling you about a serious accounting exposure, CrowdStrike uses the more awkward term, “recognition of revenue.” It’s not just evasive. It’s also where the word ‘sleazy’ enters the chat. It’s not hard to imagine this is catnip for the plaintiff’s bar. You can also drive a truck through that word lawyers love – certain; as in “certain customers.” **Here’s what’s missing from this disclosure today:** - The best practice here is to call this a revenue recognition matter and not play these word games that make the exposure hard to find. Those “certain customers” are never named, nor is the scale of the exposure quantified. Who are these customers? How big is the exposure? The initial disclosure has been repeated verbatim, not updated, since first disclosed in Jun-2025\. As such, we also cannot tell if the exposure expanded, went beyond “certain customers”, or even into other accounting areas. ### Closing Thoughts Revenue recognition has historically been one of the leading causes of restatements. Yet each quarter, since the SEC/DOJ investigations into revenue recognition were first disclosed in Jun-2025, CrowdStrike assured us “our disclosure controls and procedures were effective.” This is worth watching. We also note the lack of discussion regarding what, if any, outside resources the Board and Audit Committee have brought in to help with these investigations. Often, we will hear that forensic accountants or outside law firms have been brought in. This is worth asking about. ***– John P. Gavin, CFA, NACD.DC*** ### SEC Investigation Updates - August 19, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-august-19-2026/ Last updated: 2026-08-19T01:00:32.000Z ## [***Read full SEC Investigation Update Report here***](https://www.disclosureinsight.com/content/files/2026/08/SIU-Report---NF---2026-0819.pdf) [Subscribe](#/portal/signup) > **Service Note: Disclosure Insight will soon have a paywall for those readers who want priority access to all DI research reports going forward.** The period of free access to most of our research work will soon end. > A limited number of new All‑Access institutional engagements will be reserved for those who need direct analyst access. This access is on a highly selective basis. If interested, contact us to further discuss. ### Since Trump’s Return, Undisclosed SEC Investigations Tracked by Disclosure Insight Are Down 70% URL: https://www.disclosureinsight.com/since-trumps-return-undisclosed-sec-investigations-tracked-by-disclosure-insight-are-down-70/ Last updated: 2026-08-19T01:02:48.000Z August 2026 marks the lowest number of confirmed, undisclosed SEC investigations we have ever tracked in our 26-year history. Our August 2nd update to the DI Watch List has just 36 U.S.-registered companies with confirmed, undisclosed SEC investigations — down 70%, or 83 fewer, from the 119 we were tracking early in the Trump 47 term. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/08/2026-08-14_15-45-44.png) Historically, we typically tracked about 80–100 undisclosed SEC probes. The White House, SEC Chair Paul Atkins, and the SEC’s Republican-only Commission have made their priorities clear. ## The Value of the DI Watch List Is Even Greater Now The current DI Watch List is considerably smaller than at any time in our history. Yet, this adds greater significance to the companies that remain on it. **Why is that?** In this environment, companies added to, or remaining on the DI Watch List are those with active-and-ongoing investigations, of course. But this is also in an environment where the SEC has clearly demonstrated it is being far more selective now in who it investigates. To illustrate, among those companies that have disclosed SEC investigations, many of the matters under investigation are quite serious and, to our assessment, pose significant risk to investors. Best as we can tell, the dramatic drop in undisclosed SEC investigations is not a function of public companies having suddenly decided to disclose their SEC probes more than was the case in the past. We see little indication of that. [Subscribe now](#/portal/signup) > **Service Note: Disclosure Insight will soon have a paywall for those who want priority access to all DI research reports going forward.** The period of free access to most of our research work will soon end. > A limited number of new All‑Access institutional engagements will be reserved for those who need direct analyst access. This access is on a highly selective basis. If interested, contact us to further discuss ### *\*\* \* The balance of this note is for those unfamiliar with our work.* ### How Does Disclosure Insight Know a Public Company has an Undisclosed SEC Investigation? When we alert you to existence of an undisclosed SEC probe, that means we filed a Freedom of Information Act (FOIA) request with the United States Securities and Exchange Commission (SEC) on the public company in question and have a response, in black-and-white, on government letterhead that supports our statement. **Early Signals®** The first indicator of an undisclosed SEC investigation at a public company comes in the form of a letter from the SEC's Office of FOIA Services in response to one of our requests. The letter cites the so-called "law enforcement exemption" of the FOIA as basis to block our access to the detailed records on the public company. We call this an early signal of a possible SEC investigation. We regularly publish a report listing these findings. **Confirmation of the Signal** Confirmation of that Early Signal, when it comes, is in the form of a response from the General Counsel of the SEC to an administrative appeal we filed on an earlier FOIA response. In both cases, Early Signal and confirmation of an active-and-ongoing probe, as a matter of law, the SEC is acknowledging some sort of investigative activity. At both the Early Signal and the Confirmation stages, the SEC will not yet disclose the details of the investigative activity blocking our access to records. If we have a response from the SEC that makes clear there is ongoing enforcement activity at a public company, and we can find no clear disclosures of SEC investigative activity made by that same company, we then add it to the DI Watch List of Companies with Confirmed, Undisclosed SEC Investigations. **The paper trail supporting our work is fully documented.** FOIA requests are created and filed solely by us. Responses from the government to our requests are addressed and sent directly to us. Each year we file about 2,500 FOIA requests and hundreds of administrative appeals with the SEC and, sometimes, other agencies. We’ve been doing this since the year 2000\. ### *\- Disclosure Insight*®** ### All-access clients are invited to contact us anytime to discuss any company. *Disclosure Insight research provides data, commentary, and analysis on public company interactions with investors and with the SEC. Our work is heavily reliant on company disclosures and our expertise in using the Freedom of Information Act.*This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission. **Important**: **The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security**. **Copyright Warning and Notice** The works of authorship contained in the accompanying material, including but not limited to all data, design, text, images, charts and other data compilations or collective works are owned by Disclosure Insight, Inc. or one of its affiliates and may not be copied, reproduced, transmitted, displayed, performed, distributed, rented, sublicensed, altered, or stored for subsequent use, in whole or in part in any manner, without the prior written consent of Disclosure Insight, Inc. Photocopying or electronic distribution of any of the accompanying material or contents without the prior written consent of Disclosure Insight, Inc. violates U.S. copyright law, and may be punishable by statutory damages of up to $150,000 per infringement, plus attorneys’ fees (17 USC 504 et. seq.). Without advance permission, illegal copying includes regular photocopying, faxing, excerpting, forwarding electronically, and sharing of online access. **Intellectual Property** © 2016-2026, Disclosure Insight, Inc. All rights reserved. Disclosure Insight®; Probes Reporter®; They Know it. Now You Know It.®; Better Disclosure for Better Decisions®; Assess the Risk. Achieve the Return™; DI®; Early Signals™;and, Disclosure Games®, are trademarks of Probes Reporter, LLC and are proprietary. ### DI's Early Signals Report: August 08, 2026 URL: https://www.disclosureinsight.com/dis-early-signals-report-august-08-2026/ Last updated: 2026-08-08T14:35:22.000Z ### Companies in today's report - **ADMA Biologics, Inc. - ADMA** **AECOM - ACM** **Boeing Company, The - BA** **Hims & Hers Health, Inc. - HIMS** **Novartis AG - NVS** **Optimum Communications, Inc., fka, Altice USA, Inc. - OPTU/ATUS** **Sable Offshore Corp. - SOC** **Samsara, Inc. - IOT** **State Street Corporation - STT** **Tradeweb Markets, Inc. - TW** **Western Alliance Bancorporation - WAL** ## [***Read full Early Signals Report here***](https://www.disclosureinsight.com/content/files/2026/08/DI-Early-Signals---FS---2026-0808-1.pdf) [Subscribe](#/portal/signup) | **The July SEC FOIA Logs Were Posted This Week** | | ------------------------------------------------ | Are you curious about who else recently got indicators of possible SEC investigative activity? We call these Early Signals. The FOIA logs let you see all of the signals we, and others, got last month. **DI subscribers are first to see the Early Signals of possible ongoing SEC investigations we get.** We already published on many of them, weeks ago. DI subscribers know that having reliable research early matters. **We also tell you whether these investigations are disclosed.** This takes a lot of time and no one else does this for you. Here’s where you can see the [**July SEC FOIA logs**](https://www.sec.gov/foia/frequently-requested-documents/foia-logs?ref=disclosureinsight.com). > **Service Note: Disclosure Insight will soon have a paywall for those readers who want priority access to all DI research reports going forward.** The period of free access to most of our research work will soon end. > A limited number of new All‑Access institutional engagements will be reserved for those who need direct analyst access. This access is on a highly selective basis. If interested, contact us to further discuss. ### SEC Investigation Updates - August 07, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-august-07-2026/ Last updated: 2026-08-07T01:42:37.000Z ## [***Read full SEC Investigation Update Report here***](https://www.disclosureinsight.com/content/files/2026/08/SIU-Report---NF---2026-0807-1.pdf) [Subscribe](#/portal/signup) > **Service Note: Disclosure Insight will soon have a paywall for those readers who want priority access to all DI research reports going forward.** The period of free access to most of our research work will soon end. > A limited number of new All‑Access institutional engagements will be reserved for those who need direct analyst access. This access is on a highly selective basis. If interested, contact us to further discuss. ### SEC Investigation Updates: July 27, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-july-27-2026/ Last updated: 2026-07-27T00:03:04.000Z ### Click on the PDF *below* the table to access today’s report [SEC Investigation Updates - July 27, 2026SIU Report - FS - 2026-0727.pdf938 KBdownload-circle](https://www.disclosureinsight.com/content/files/2026/07/SIU-Report---FS---2026-0727.pdf "Download") **All-access clients are invited to contact us anytime to discuss any company.** *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* [Subscribe now](#/portal/signup) ### DI's Early Signals Report: July 22, 2026 URL: https://www.disclosureinsight.com/dis-early-signals-report-july-22/ Last updated: 2026-07-23T23:25:46.000Z ***Click on the PDF here to access this report*** [DI's Early Signals Report: July 22, 2026DI's Early Signals Report: July 22, 2026413 KBdownload-circle](https://direports.substack.com/api/v1/file/9515248f-4fc2-4a34-8908-db149c27353e.pdf "Download") [Subscribe now](#/portal/signup) ### What’s an Early Signal? **DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity**. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation as “confirmed” after we file an administrative appeal and have received a response that says as much. **Important**: **The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security**. In its responses, the SEC did not disclose the details on investigative activity referenced herein. They may pertain to the conduct, transactions, and/or disclosures of the companies; but that is not yet confirmed. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. At this point, we believe the investigation does pertain to the conduct, transactions, and/or disclosures of the companies. 2. There is an investigation in the present day in which enforcement proceedings remain ongoing, however, they only relate to the company. An example is when a company gets caught up is a larger multi-company investigation that remains ongoing, but the company is no longer directly involved. 3. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 4. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 5. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. **All-access clients are welcome to contact us anytime to learn more.** ### DI Watch List - July 01, 2026 URL: https://www.disclosureinsight.com/di-watch-list-july-01-2026/ Last updated: 2026-07-03T18:01:27.000Z #### *Click on the printable PDF below to access the full DI Watch List.* [DI Watch List - July 01, 2026DI Watch List - July 01, 20264 MBdownload-circle](https://www.disclosureinsight.com/api/v1/file/35415412-e6ff-477e-b143-b601111f87d8.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) **As a reminder,** a company will only appear on the DI Watch List if we believe the ongoing and undisclosed SEC investigative activity we find directly pertains to its conduct, transactions, and/or disclosures. **If you’re a professional interested in learning more about our all-access service level, feel free to email or call me.** No matter your service level, my goal is to help you make money and, above all, avoid losses. **Please tell others.** As always, thank you for your support. *\- John* ***John P. Gavin, CFA, NACD.DC*** > **Service Note:** Access to DI research will become more structured in the new year, with a dedicated tier for readers who want content only and a very limited number of new All‑Access institutional engagements for those who need direct analyst access. If you rely on this work, this is a good moment to stay close. *When we alert you to existence of an undisclosed SEC probe, that means we filed a Freedom of Information Act (FOIA) request with the United States Securities and Exchange Commission (SEC) on the company in question and have a response, in black-and-white, on government letterhead that supports our statement. The only thing we know at this time is that the investigation(s) somehow pertains to the conduct, transactions, and/or disclosures of the companies referenced.* This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission. [Subscribe](#/portal/signup) ### DI's Early Signals Report: June 30, 2026 URL: https://www.disclosureinsight.com/dis-early-signals-report-june-30/ Last updated: 2026-07-03T18:01:27.000Z ***Click on the PDF here to access this report*** [DI's Early Signals Report: June 30, 2026DI's Early Signals Report: June 30, 2026422 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/4b0c131a-df9d-462a-9f53-98fae91c6875.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What’s an Early Signal? **DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity**. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation as “confirmed” after we file an administrative appeal and have received a response that says as much. **Important**: **The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security**. In its responses, the SEC did not disclose the details on investigative activity referenced herein. They may pertain to the conduct, transactions, and/or disclosures of the companies; but that is not yet confirmed. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. At this point, we believe the investigation does pertain to the conduct, transactions, and/or disclosures of the companies. 2. There is an investigation in the present day in which enforcement proceedings remain ongoing, however, they only relate to the company. An example is when a company gets caught up is a larger multi-company investigation that remains ongoing, but the company is no longer directly involved. 3. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 4. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 5. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. **All-access clients are welcome to contact us anytime to learn more.** ### SEC Investigation Updates: June 29, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-june-29/ Last updated: 2026-07-03T18:01:28.000Z ### Click on the PDF *below* the table to access today’s report [SEC Investigation Updates - June 29, 2026SEC Investigation Updates - June 29, 2026479 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/a9ca4dc7-b8c6-4045-b99a-0834d6d96277.pdf "Download") **All-access clients are invited to contact us anytime to discuss any company.** *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* [Subscribe now](https://www.disclosureinsight.com/subscribe) ### SEC Investigation Updates - June 23, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-june-23/ Last updated: 2026-07-03T18:01:28.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - June 23, 2026SEC Investigation Updates - NF - June 23, 2026396 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/125ab501-82f7-4dfe-8aaa-d1e7f6f23837.pdf "Download") [Subscribe](#/portal/signup) ### DI Alert: Carvana and the SEC’s Complex Financial Instruments Unit URL: https://www.disclosureinsight.com/di-alert-carvana-and-the-secs-complex/ Last updated: 2026-07-03T18:01:28.000Z #### ***Click here to get a printable PDF of today’s report.*** [DI Alert: Carvana - CVNA 2026 0617DI Alert: Carvana - CVNA 2026 0617659 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/def499ac-70d8-4c9f-8696-68423b0e1800.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### DI Alert: Hub Group - Accounting Problems Getting Worse URL: https://www.disclosureinsight.com/di-alert-hub-group-accounting-problems/ Last updated: 2026-07-03T18:01:29.000Z #### ***Click here to get a printable PDF of today’s report.*** [DI Alert: Hub Group – HUBG 2026-0611DI Alert: Hub Group – HUBG 2026-0611573 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/19612736-a9ab-4819-a9f6-a06f2c1626ef.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### SEC Investigation Updates - June 09, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-june-09/ Last updated: 2026-07-03T18:01:29.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - June 09, 2026SEC Investigation Updates - NF - June 09, 2026395 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/fc5d7688-5fda-4994-8211-ce00abda4aa2.pdf "Download") [Subscribe](#/portal/signup) ### DI's Early Signals Report: May 29, 2026 URL: https://www.disclosureinsight.com/dis-early-signals-report-may-29-2026/ Last updated: 2026-07-03T18:01:29.000Z ***Click on the PDF here to access this report*** [DI's Early Signals Report: May 29, 2026DI's Early Signals Report: May 29, 2026420 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/af8425d2-1f4b-42a7-b47b-c7dbab6b5503.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What’s an Early Signal? **DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity**. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation as “confirmed” after we file an administrative appeal and have received a response that says as much. **Important**: **The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security**. In its responses, the SEC did not disclose the details on investigative activity referenced herein. They may pertain to the conduct, transactions, and/or disclosures of the companies; but that is not yet confirmed. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. At this point, we believe the investigation does pertain to the conduct, transactions, and/or disclosures of the companies. 2. There is an investigation in the present day in which enforcement proceedings remain ongoing, however, they only relate to the company. An example is when a company gets caught up is a larger multi-company investigation that remains ongoing, but the company is no longer directly involved. 3. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 4. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 5. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. **All-access clients are welcome to contact us anytime to learn more.** ### SEC Investigation Updates: May 28, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-may-28-a7e-2/ Last updated: 2026-07-23T23:25:50.000Z ### Click on the PDF *below* the table to access today’s report ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/07/d7595e03-43fd-44d7-bece-37dd5c31cf4e_776x669-2.png) [SEC Investigation Updates - May 28, 2026SEC Investigation Updates - May 28, 2026470 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/c16965e2-d739-4e1f-b78f-bb76089767b1.pdf "Download") **All-access clients are invited to contact us anytime to discuss any company.** *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* [Subscribe now](#/portal/signup) ### SEC Investigation Updates - May 27, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-may-27/ Last updated: 2026-07-03T18:01:30.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - May 27, 2026SEC Investigation Updates - NF - May 27, 2026443 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/05e48d05-998e-4050-880b-69b93c9337d0.pdf "Download") [Subscribe](#/portal/signup) ### SEC Investigation Updates - May 07, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-may-07/ Last updated: 2026-07-03T18:01:30.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - May 07, 2026SEC Investigation Updates - NF - May 07, 2026398 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/73734cb4-8d9b-445c-ab6d-b4133bc96888.pdf "Download") [Subscribe](#/portal/signup) ### SEC Investigation Updates - May 04, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-may-04/ Last updated: 2026-07-03T18:01:31.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - May 04, 2026SEC Investigation Updates - NF - May 04, 2026443 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/a161c074-b026-4396-9f11-3414457f4e6e.pdf "Download") [Subscribe](#/portal/signup) ### DI's Early Signals Report: April 30, 2026 URL: https://www.disclosureinsight.com/dis-early-signals-report-april-30/ Last updated: 2026-07-03T18:01:31.000Z ***Click on the PDF here to access this report*** [DI's Early Signals Report: April 30, 2026DI's Early Signals Report: April 30, 2026415 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/2bff5fab-caeb-49a8-8b68-2cfcecbe1c3d.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What’s an Early Signal? **DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity**. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation as “confirmed” after we file an administrative appeal and have received a response that says as much. **Important**: **The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security**. In its responses, the SEC did not disclose the details on investigative activity referenced herein. They may pertain to the conduct, transactions, and/or disclosures of the companies; but that is not yet confirmed. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. At this point, we believe the investigation does pertain to the conduct, transactions, and/or disclosures of the companies. 2. There is an investigation in the present day in which enforcement proceedings remain ongoing, however, they only relate to the company. An example is when a company gets caught up is a larger multi-company investigation that remains ongoing, but the company is no longer directly involved. 3. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 4. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 5. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. **All-access clients are welcome to contact us anytime to learn more.** ### Staying Sharp URL: https://www.disclosureinsight.com/staying-sharp/ Last updated: 2026-08-21T17:24:32.000Z This month, after over 40 years on Wall Street, I went back into the classroom through a Wharton executive education program, *Family Wealth Management: Advanced Financial Strategies*. I loved it - no surprise there. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/07/500dc199-f8f3-4e05-889a-6f3f11d3e27f_800x620.png) This program went well beyond traditional public markets, the core focus of my work at Disclosure Insight. [Subscribe](#/portal/signup) **We learned what families are allocating into and, notably, where they are growing more cautious.** This included considerable time on - - Private equity; Private credit; Real estate; Other alternatives; and, How risk is being managed across increasingly complex structures. It was interesting to hear what is now happening **at the exit stage**, where **friction is starting to show up in ways unexpected.** From the reactions of fellow students and instructors, I get the sense there’s growing nervousness around alternative assets. Watch this space. **We also spent time on governance** and how it differs between families, private companies, and institutions - **and where it tends to break down for high net worth families**. One theme came up repeatedly: **Sustaining wealth across generations is more fragile than most assume**. Those patterns are remarkably consistent across regions and cultures - but they can be mitigated with the right structures. This new learning should help with my work at Disclosure Insight and also with my board work outside of DI. **As many of you know, in recent years I have pursued formal board training**, including becoming Director Certified by the National Association of Corporate Directors in early 2025 (the NACD.DC you now see after my name). I am also a member of the Private Directors Association. I have served on nonprofit boards and currently serve on advisory boards at my college and a private cybersecurity company. My time at Wharton builds on all of this, **particularly for private company boards and family office investment committees.** Thanks for taking a moment out of your busy earnings season for this personal update. Back to the research grind now … As always, I thank you for your ongoing support — *John* - ***John P. Gavin, CFA, NACD.DC*** [Subscribe now](https://www.disclosureinsight.com/subscribe) [Subscribe](#/portal/signup) ### SEC Investigation Updates - April 23, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-april-23-2/ Last updated: 2026-07-23T23:25:52.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - April 23, 2026SEC Investigation Updates - NF - April 23, 2026445 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/5465233c-b27c-41c2-9678-325a3358b77d.pdf "Download") [Subscribe](#/portal/signup) ### DI's Early Signals Report: April 22, 2026 URL: https://www.disclosureinsight.com/dis-early-signals-report-april-22/ Last updated: 2026-07-03T18:01:32.000Z ***Click on the PDF here to access this report*** [DI's Early Signals Report: April 22, 2026DI's Early Signals Report: April 22, 2026428 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/e4f993d2-c5a9-4b0f-85f8-ab406c8532f2.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What’s an Early Signal? **DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity**. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation as “confirmed” after we file an administrative appeal and have received a response that says as much. **Important**: **The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security**. In its responses, the SEC did not disclose the details on investigative activity referenced herein. They may pertain to the conduct, transactions, and/or disclosures of the companies; but that is not yet confirmed. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. At this point, we believe the investigation does pertain to the conduct, transactions, and/or disclosures of the companies. 2. There is an investigation in the present day in which enforcement proceedings remain ongoing, however, they only relate to the company. An example is when a company gets caught up is a larger multi-company investigation that remains ongoing, but the company is no longer directly involved. 3. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 4. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 5. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. **All-access clients are welcome to contact us anytime to learn more.** ### SEC Investigation Updates - April 15, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-april-15/ Last updated: 2026-07-03T18:01:32.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - April 15, 2026SEC Investigation Updates - NF - April 15, 2026389 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/26341b0c-2820-4acd-90f2-4453a2226b32.pdf "Download") [Subscribe](#/portal/signup) ### DI Alert: FactSet - Abrupt Departure of the CFO URL: https://www.disclosureinsight.com/di-alert-factset-abrupt-departure/ Last updated: 2026-07-03T18:01:32.000Z #### ***Click here to get a printable PDF of today’s report.*** [DI Alert: FactSet Research Systems FDS 2026-0412DI Alert: FactSet Research Systems FDS 2026-0412376 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/eb817135-95f0-4cda-ad81-41b8b74e9ecc.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### DI's Early Signals Report: April 12, 2026 URL: https://www.disclosureinsight.com/dis-early-signals-report-april-12/ Last updated: 2026-07-03T18:01:33.000Z ***Click on the PDF here to access this report*** [DI's Early Signals Report: April 12, 2026DI's Early Signals Report: April 12, 2026423 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/b891face-3c4c-42b0-aff5-2fe46c7e6a93.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What’s an Early Signal? **DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity**. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation as “confirmed” after we file an administrative appeal and have received a response that says as much. **Important**: **The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security**. In its responses, the SEC did not disclose the details on investigative activity referenced herein. They may pertain to the conduct, transactions, and/or disclosures of the companies; but that is not yet confirmed. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. At this point, we believe the investigation does pertain to the conduct, transactions, and/or disclosures of the companies. 2. There is an investigation in the present day in which enforcement proceedings remain ongoing, however, they only relate to the company. An example is when a company gets caught up is a larger multi-company investigation that remains ongoing, but the company is no longer directly involved. 3. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 4. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 5. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. **All-access clients are welcome to contact us anytime to learn more.** ### DI's Early Signals Report: April 08, 2026 URL: https://www.disclosureinsight.com/dis-early-signals-report-april-08/ Last updated: 2026-07-03T18:01:33.000Z ***Click on the PDF here to access this report*** [DI's Early Signals Report: April 08, 2026DI's Early Signals Report: April 08, 2026412 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/6ea8eec3-805b-45a0-ac0a-3a18c8498ba1.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What’s an Early Signal? **DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity**. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation as “confirmed” after we file an administrative appeal and have received a response that says as much. **Important**: **The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security**. In its responses, the SEC did not disclose the details on investigative activity referenced herein. They may pertain to the conduct, transactions, and/or disclosures of the companies; but that is not yet confirmed. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. At this point, we believe the investigation does pertain to the conduct, transactions, and/or disclosures of the companies. 2. There is an investigation in the present day in which enforcement proceedings remain ongoing, however, they only relate to the company. An example is when a company gets caught up is a larger multi-company investigation that remains ongoing, but the company is no longer directly involved. 3. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 4. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 5. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. **All-access clients are welcome to contact us anytime to learn more.** ### DI Watch List - April 02, 2026 URL: https://www.disclosureinsight.com/di-watch-list-april-02-2026-2/ Last updated: 2026-07-23T23:25:54.000Z #### *Click on the printable PDF below to access the full DI Watch List.* [DI Watch List - April 02, 2026DI Watch List - April 02, 20264 MBdownload-circle](https://www.disclosureinsight.com/api/v1/file/75d66517-7026-40cc-bcad-9870d503859f.pdf "Download") [Subscribe now](#/portal/signup) **As a reminder,** a company will only appear on the DI Watch List if we believe the ongoing and undisclosed SEC investigative activity we find directly pertains to its conduct, transactions, and/or disclosures. **If you’re a professional interested in learning more about our all-access service level, feel free to email or call me.** No matter your service level, my goal is to help you make money and, above all, avoid losses. **Please tell others.** As always, thank you for your support. *\- John* ***John P. Gavin, CFA, NACD.DC*** > **Service Note:** Access to DI research will become more structured in the new year, with a dedicated tier for readers who want content only and a very limited number of new All‑Access institutional engagements for those who need direct analyst access. If you rely on this work, this is a good moment to stay close. *When we alert you to existence of an undisclosed SEC probe, that means we filed a Freedom of Information Act (FOIA) request with the United States Securities and Exchange Commission (SEC) on the company in question and have a response, in black-and-white, on government letterhead that supports our statement. The only thing we know at this time is that the investigation(s) somehow pertains to the conduct, transactions, and/or disclosures of the companies referenced.* This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission. [Subscribe](#/portal/signup) ### SEC Investigation Updates: April 01, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-april-01-3/ Last updated: 2026-07-23T23:25:54.000Z ### Click on the PDF *below* the table to access today’s report ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/07/8658f46c-92c6-47ad-af63-dcc6406786e2_763x710-2.png) [SEC Investigation Updates - April 01, 2026SEC Investigation Updates - April 01, 2026428 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/de5a343f-4644-4925-ab6a-79c548f07065.pdf "Download") **All-access clients are invited to contact us anytime to discuss any company.** [Subscribe](#/portal/signup) *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* ### SEC Investigation Updates - March 31, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-march-31-2/ Last updated: 2026-07-23T23:25:55.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - March 31 2026SEC Investigation Updates - NF - March 31 2026435 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/33f1519e-ff16-491b-a449-4c4427dff77e.pdf "Download") [Subscribe](#/portal/signup) ### SEC Investigation Updates - March 17, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-march-17/ Last updated: 2026-03-17T13:49:00.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - March 17, 2026SEC Investigation Updates - NF - March 17, 2026404 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/3c538977-71ff-4a24-bf94-718e7b35d296.pdf "Download") [Subscribe](#/portal/signup) ### DI's Early Signals Report: March 12, 2026 URL: https://www.disclosureinsight.com/dis-early-signals-report-march-12-4d0-2/ Last updated: 2026-07-03T18:01:37.000Z ***Click on the PDF here to access this report*** [DI's Early Signals Report: Marc h 12, 2026DI's Early Signals Report: Marc h 12, 2026429 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/860274d4-1419-4bf4-92f5-5e8ad1947b3d.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What’s an Early Signal? **DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity**. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation as “confirmed” after we file an administrative appeal and have received a response that says as much. **Important**: **The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security**. In its responses, the SEC did not disclose the details on investigative activity referenced herein. They may pertain to the conduct, transactions, and/or disclosures of the companies; but that is not yet confirmed. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. At this point, we believe the investigation does pertain to the conduct, transactions, and/or disclosures of the companies. 2. There is an investigation in the present day in which enforcement proceedings remain ongoing, however, they only relate to the company. An example is when a company gets caught up is a larger multi-company investigation that remains ongoing, but the company is no longer directly involved. 3. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 4. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 5. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. **All-access clients are welcome to contact us anytime to learn more.** ### DI Watch List - March 02, 2026 URL: https://www.disclosureinsight.com/di-watch-list-march-02-2026/ Last updated: 2026-03-17T13:49:00.000Z #### *Click on the printable PDF below to access the fill D.I. Watch List.* [DI Watch List - March 02, 2026DI Watch List - March 02, 2026427 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/672cd570-7588-46a4-8225-0ba9832d4399.pdf "Download") #### *This is the new warning on Freedom Holding (FRHC) we referenced in today’s Watch List.* [NEW DI Report: Freedom Holding - FRHC 2026-0301NEW DI Report: Freedom Holding - FRHC 2026-0301473 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/fa2b5cd5-fab6-48e8-9e10-100a24551123.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) **As a reminder,** a company will only appear on the DI Watch List if we believe the ongoing and undisclosed SEC investigative activity we find directly pertains to its conduct, transactions, and/or disclosures. **If you’re a professional interested in learning more about our all-access service level, feel free to email or call me.** No matter your service level, my goal is to help you make money and, above all, avoid losses. **Please tell others.** As always, thank you for your support. *\- John* ***John P. Gavin, CFA, NACD.DC*** > **Service Note:** Access to DI research will become more structured in the new year, with a dedicated tier for readers who want content only and a very limited number of new All‑Access institutional engagements for those who need direct analyst access. If you rely on this work, this is a good moment to stay close. *When we alert you to existence of an undisclosed SEC probe, that means we filed a Freedom of Information Act (FOIA) request with the United States Securities and Exchange Commission (SEC) on the company in question and have a response, in black-and-white, on government letterhead that supports our statement. The only thing we know at this time is that the investigation(s) somehow pertains to the conduct, transactions, and/or disclosures of the companies referenced.* This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission. [Subscribe](#/portal/signup) ### Freedom Holding’s Sudden Transparency Raises Bigger Questions URL: https://www.disclosureinsight.com/freedom-holdings-sudden-transparency/ Last updated: 2026-03-17T13:49:00.000Z #### ***Click here to get a printable PDF of today’s report.*** [DI Report: Freedom Holding - FRHC 2026-0301DI Report: Freedom Holding - FRHC 2026-0301473 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/be036f89-5c22-4b05-abef-139e33779064.pdf "Download") ## *Warning on a Newly Disclosed SEC Investigation* ### Summary & Opinion: Heads up – One of the dirtiest companies we follow and warned on repeatedly has given us a gift. Freedom Holding (FRHC) finally disclosed the SEC investigation we first found in October 2021\. As one does when in the company of a pack of thieves, we’ll adopt the vernacular and note Freedom Holding is now singing like a canary about its own SEC investigation. But why? This level of detail and transparency is way out of character for this company. We have an idea or few on this. To us, even in this light-touch SEC environment, it’s clear Freedom Holding’s SEC investigation has gone south. If correct, this disclosure reads more confessional than anything else. It’s that “come-to-Jesus” disclosure your lawyers craft for you to provide defenses later – you know, when things go bad and investors try claiming they were left in the dark. Therein lies the gift. It appears insiders know bad news is coming. Soon. Very soon. [Subscribe now](https://www.disclosureinsight.com/subscribe) **From the Freedom Holding 10-Q filed 09-Feb-2026:** > Since 2021, the Company and certain officers and directors have received several document subpoenas, document requests and subpoenas and requests for testimony from the SEC’s Division of Enforcement. The requested information relates to a number of topics, including the settlement practices and relationships with certain institutional market makers of certain of non-U.S. broker-dealer subsidiaries, and has included our accounting practices, disclosures, and internal controls. The matter is ongoing, and the Company is cooperating with the SEC. The Company face risks and uncertainties relating to the duration, outcome or impact of the inquiry on its business, including the amount of any fines or other penalties. Any of the foregoing could, individually or in the aggregate, materially adversely affect, the Company’s reputation, business, financial condition, results of operations, prospects, and cash flows. ### DI’s Take: We received our early signal of an undisclosed SEC investigation at Freedom Holding in Oct-2021 and warned repeatedly on it since. We went further, also calling this one of dirtiest companies we follow. Its investigation now disclosed, FRHC is removed from the DI Watch List of companies with undisclosed SEC probes. Given the history we found here, this first-time disclosure of its long-running SEC investigation is not likely indicative of a company newly committed to transparency. It was already under investigation by the time Hindenburg Research issued its warning in Aug-2023\. Yet the company said nothing about SEC involvement then – nor when rebutting that report in Jan-2024. There’s also no disclosure language to suggest the SEC investigation is nearing its end, nor is it likely to close with a wrist slap or small penalty. Instead, Freedom Holding warns of a wide array of potential consequences from the SEC probe, some of which could easily be severe. ### Developments of Note: Like us, the auditor had concerns years ago at Freedom Holding. In Jul‑2022, the auditor at the time declined re‑appointment for the fiscal year ending 31‑Mar‑2023 — and bolted much earlier, at the end of the Jun‑2022 quarter. That is extremely rare. Apparently, the auditor saw enough to want out fast. - **DI’s Early Signal of undisclosed SEC probe: Oct-2021.** - Abrupt departure of auditor: Jul‑2022. - Two restatements: Nov-2022 and Mar-2023. - Long-running internal controls problems. - Multiple delayed SEC filings (10 Ks and 10 Qs). - Repeated Nasdaq non-compliance/de-listing notices - Big fat raises for C-suite executives announced same day of a second delisting notice: Aug-2023. - ***Hindenburg Research*** warning, Aug-2023,[Brazen Sanctions Evasion, Hallmarks of Fabricated Revenue and Risky Bets with Commingled Customer Funds](https://hindenburgresearch.com/freedom/?ref=disclosureinsight.com) ***– John P. Gavin, CFA, NACD.DC*** [Subscribe](#/portal/signup) ### Assess the Risk. Achieve the Return.® *Disclosure Insight research provides data, commentary, and analysis on public company interactions with investors and with the SEC. Our work is heavily reliant on company disclosures and our expertise in using the Freedom of Information Act.* This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission. **Copyright Warning and Notice** The works of authorship contained in the accompanying material, including but not limited to all data, design, text, images, charts and other data compilations or collective works are owned by Disclosure Insight, Inc. or one of its affiliates and may not be copied, reproduced, transmitted, displayed, performed, distributed, rented, sublicensed, altered, or stored for subsequent use, in whole or in part in any manner, without the prior written consent of Disclosure Insight, Inc. 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Achieve the Return™; DI®; Early Signals™;and, Disclosure Games®, are trademarks of Probes Reporter, LLC and are proprietary. ### SEC Investigation Updates - February 27, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-february-747-3/ Last updated: 2026-07-23T23:25:56.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - February 27, 2026SEC Investigation Updates - NF - February 27, 2026466 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/b8f84772-1e5d-4a34-b244-43f2d67fc0db.pdf "Download") [Subscribe](#/portal/signup) ### SEC Investigation Updates - February 17, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-february-9fe-3/ Last updated: 2026-07-23T23:25:56.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - February 17, 2026SEC Investigation Updates - NF - February 17, 2026283 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/04c8b617-c767-492d-82de-9e4fa38f7bcd.pdf "Download") [Subscribe](#/portal/signup) ### SEC Investigation Updates - February 10, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-february-7bc-3/ Last updated: 2026-07-23T23:25:57.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - February 10, 2026SEC Investigation Updates - NF - February 10, 2026285 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/6d4911ec-abe4-4311-8689-126000b868ee.pdf "Download") [Subscribe](#/portal/signup) ### DI's Early Signals Report: February 08, 2026 URL: https://www.disclosureinsight.com/dis-early-signals-report-february-bbc/ Last updated: 2026-03-17T13:49:01.000Z ***Click on the PDF here to access a printable version of this report.*** [DI's Early Signals Report: February 08, 2026DI's Early Signals Report: February 08, 2026317 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/40fdfb7b-fba0-49b7-9116-af937505fb82.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) > **Service Note:** Access to DI research will become more structured in the new year, with a dedicated tier for readers who want content only and a very limited number of new All‑Access institutional engagements for those who need direct analyst access. If you rely on this work, this is a good moment to stay close. ### What’s an Early Signal? **DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity**. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation as “confirmed” after we file an administrative appeal and have received a response that says as much. **Important**: **The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security**. In its responses, the SEC did not disclose the details on investigative activity referenced herein. They may pertain to the conduct, transactions, and/or disclosures of the companies; but that is not yet confirmed. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. At this point, we believe the investigation does pertain to the conduct, transactions, and/or disclosures of the companies. 2. There is an investigation in the present day in which enforcement proceedings remain ongoing, however, they only relate to the company. An example is when a company gets caught up is a larger multi-company investigation that remains ongoing, but the company is no longer directly involved. 3. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 4. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 5. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. **All-access clients are welcome to contact us anytime to learn more.** ### Uber Technologies: Departure of CFO on Short Notice - 3rd CFO since 2023 URL: https://www.disclosureinsight.com/uber-technologies-departure-of-cfo/ Last updated: 2026-03-17T13:49:01.000Z ### Uber Technologies, Inc. – UBER On 04-Feb-2026, Uber announced its CFO, Prashanth Mahendra-Rajah, will leave the role, effective 16-Feb-2026\. His replacement will be Uber’s third CFO since 2023\. We’ve also been tracking an undisclosed SEC investigation at Uber since Jan-2025 ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/aa882879-b242-4503-b8e2-f67fb4fee863_821x178.png) In 2025, Uber filed its 10-K on 14-Feb-2025\. It looks like the current CFO is leaving just as the 2026 one is due. When the new 10-K comes out, watch for who’s listed as CFO. If Mahendra-Rajah isn’t listed as CFO, that suggests he didn’t want to be accountable for it - not a good sign. ### The CFO Departure **Per the Uber Technologies 8-K filed 04-Feb-2026 –** > On February 4, 2026, Uber Technologies, Inc. (the “Company”) announced that Prashanth Mahendra-Rajah, Chief Financial Officer, will step down from his role on February 16, 2026 … Mr. Mahendra-Rajah will serve as a Senior Finance Advisor reporting to CEO Dara Khosrowshahi through July 1, 2026. **These guys are gushing all over each other as the CFO heads toward the door. So why is he leaving so abruptly?** The answer may be found in this fluff about the company wishing “him the best in an exciting new opportunity that he will share more about soon.” Perhaps it’s nothing, but we’ve also never seen language like that regarding a CFO departure. > \[CEO Dara\] Khosrowshahi said: “I want to thank Prashanth for everything he’s done for Uber. He’s been a great partner in getting us to investment-grade status, spearheading our first share repurchase program, and steering us through several major acquisitions. **We all wish him the best in an exciting new opportunity that he will share more about soon.”** > … Mr. Mahendra-Rajah said: “I want to express my sincere gratitude to Dara and the Uber leadership team. Uber is a once-in-a-generation company with many years of extraordinary growth ahead, and it has been a true privilege to play my part in its success. I also want to congratulate Balaji, who is a superb executive and someone who I’m confident will take Uber to the next level.” ### The Undisclosed SEC Investigation In our work, the Early Signal of an undisclosed SEC investigation at Uber was first received on 17-Jan-2025, and later confirmed as an ongoing SEC investigation on 02-May-2025\. *New research in-process as of Nov-2025.* - ***John P. Gavin, CFA, NACD.DC*** [Subscribe](#/portal/signup) ### SEC Investigation Updates: January 30, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-january-189-3/ Last updated: 2026-07-23T23:25:57.000Z ### Click on the PDF *below* the table to access today’s report ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/07/e6723391-7b10-41dc-a538-5a01c55e3eb4_292x736-1.png) [SEC Investigation Updates - January 30, 2026SEC Investigation Updates - January 30, 2026289 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/cedf49b6-86fb-43db-b7c6-6700ee0ce128.pdf "Download") **All-access clients are welcome to contact us anytime to learn more.** [Subscribe](#/portal/signup) *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* ### SEC Investigation Updates: January 29, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-january-a58-3/ Last updated: 2026-07-23T23:25:58.000Z ***Click on the PDF here to access today’s report*** [SEC Investigation Updates - January 29, 2026SEC Investigation Updates - January 29, 2026284 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/89ba21b9-a0e4-4144-b8bc-ff9ab73b9213.pdf "Download") **All-access clients are welcome to contact us anytime to learn more.** [Subscribe](#/portal/signup) *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* ### SEC Investigation Updates: January 26, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-january-791/ Last updated: 2026-03-17T13:49:02.000Z ***Click on the PDF here to access today’s report*** [SEC Investigation Updates - January 26, 2026SEC Investigation Updates - January 26, 2026296 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/aef09081-25cd-4c63-9b4a-00903b342ade.pdf "Download") **All-access clients are welcome to contact us anytime to learn more.** [Subscribe](#/portal/signup) *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* ### SEC Investigation Updates - January 14, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-january-8b3/ Last updated: 2026-03-17T13:49:02.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - January 14, 2026SEC Investigation Updates - NF - January 14, 2026285 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/23fb5482-567a-41fb-96b6-898f58a6a7c0.pdf "Download") [Subscribe](#/portal/signup) ### SEC Investigation Updates - January 09, 2026 URL: https://www.disclosureinsight.com/sec-investigation-updates-january-51b-3/ Last updated: 2026-07-23T23:25:59.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - January 09, 2026SEC Investigation Updates - NF - January 09, 2026336 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/7995bc60-21a0-4479-bc4e-7b4db885f890.pdf "Download") [Subscribe](#/portal/signup) ### DI's Early Signals Report: January 07, 2026 URL: https://www.disclosureinsight.com/dis-early-signals-report-january-2f5-3/ Last updated: 2026-07-23T23:25:59.000Z ***Click on the PDF here to access a printable version of this report.*** [DI's Early Signals Report: January 07, 2026DI's Early Signals Report: January 07, 2026294 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/6607563a-5d91-45e0-8ddd-5e25b039137f.pdf "Download") [Subscribe now](#/portal/signup) > **Service Note:** Access to DI research will become more structured in the new year, with a dedicated tier for readers who want content only and a very limited number of new All‑Access institutional engagements for those who need direct analyst access. If you rely on this work, this is a good moment to stay close. ### What’s an Early Signal? **DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity**. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation as “confirmed” after we file an administrative appeal and have received a response that says as much. **Important**: **The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security**. In its responses, the SEC did not disclose the details on investigative activity referenced herein. They may pertain to the conduct, transactions, and/or disclosures of the companies; but that is not yet confirmed. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. At this point, we believe the investigation does pertain to the conduct, transactions, and/or disclosures of the companies. 2. There is an investigation in the present day in which enforcement proceedings remain ongoing, however, they only relate to the company. An example is when a company gets caught up is a larger multi-company investigation that remains ongoing, but the company is no longer directly involved. 3. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 4. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 5. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. **All-access clients are welcome to contact us anytime to learn more.** ### DI's Early Signals Report: January 06, 2026 URL: https://www.disclosureinsight.com/dis-early-signals-report-january-5a5-3/ Last updated: 2026-07-23T23:25:59.000Z ***Click on the PDF here to access a printable version of this report.*** [DI's Early Signals Report: January 06, 2026DI's Early Signals Report: January 06, 2026296 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/a85dd4cf-4a8c-43ee-b68a-078c6c380984.pdf "Download") [Subscribe now](#/portal/signup) > **Service Note:** Access to DI research will become more structured in the new year, with a dedicated tier for readers who want content only and a very limited number of new All‑Access institutional engagements for those who need direct analyst access. If you rely on this work, this is a good moment to stay close. ### What’s an Early Signal? **DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity**. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation as “confirmed” after we file an administrative appeal and have received a response that says as much. **Important**: **The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security**. In its responses, the SEC did not disclose the details on investigative activity referenced herein. They may pertain to the conduct, transactions, and/or disclosures of the companies; but that is not yet confirmed. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. At this point, we believe the investigation does pertain to the conduct, transactions, and/or disclosures of the companies. 2. There is an investigation in the present day in which enforcement proceedings remain ongoing, however, they only relate to the company. An example is when a company gets caught up is a larger multi-company investigation that remains ongoing, but the company is no longer directly involved. 3. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 4. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 5. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. **All-access clients are welcome to contact us anytime to learn more.** ### Five Unexpected “Nothing Found” FOIA Responses From the SEC URL: https://www.disclosureinsight.com/five-unexpected-nothing-found-foia/ Last updated: 2026-03-17T13:49:03.000Z ## This month’s Watch List update took an unexpected turn. Within a 10‑day period in December, we received SEC responses on five Watch List companies stating the agency “did not locate or identify any records responsive to \[our FOIA\] request.” These responses are inconsistent with responses we received within the last year on these companies. Each had previously been confirmed as having active, ongoing SEC investigative activity. Even if those investigations have since closed, we would normally expect to see some record of prior activity. Instead, we received five “nothing found” replies in close succession. **Spidey senses now tingling.** **After 25 years of tracking undisclosed SEC investigations, this pattern is unusual enough to merit a standalone alert**. It also comes as the number of companies we are tracking with confirmed but undisclosed SEC investigations has already fallen sharply — from 120 earlier in the year to 59 as of our December Watch List update. For now, each of the five companies below is being removed from the Watch List while we await more data. We will appeal each of these responses and continue to follow up as needed. The full Watch List update — including all additions, removals, and status changes — will be published Sunday evening. Full notes below the table. **Note:* A previous version of this report included a reference to Project 2025 that has been removed to uphold our standards for accuracy and non-partisanship.* [Subscribe now](https://www.disclosureinsight.com/subscribe) **All-access clients are welcome to contact us anytime to learn more.** ***Click on the PDF here to access today’s report or read full text below.*** [SEC Investigation Updates - January 04, 2026SEC Investigation Updates - January 04, 2026351 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/1d993ef3-dc7a-4a6f-ac47-4f3ef966fdc0.pdf "Download") ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/1154bc4a-bc5f-4f05-ab94-b080b3f2d40e_678x347-1.png) ## Company Comments ## CNH Industrial NV – CNHI **Removed from Watch List.** Removed while we await more data. We received a “nothing found” response on CNH on 10-Dec-2025, which is inconsistent with earlier responses. Undisclosed SEC investigation last confirmed as ongoing on 27-May-2025\. CEO resigned; announced Apr-2024, effective 01-Jul-2024\. Timing of that CEO resignation is interesting since our work suggests CNH Industrial may have known about an SEC probe since at least May-2024\. We will appeal this latest response and follow-up as needed. ## Nektar Therapeutics - NKTR **Removed from Watch List.** Removed while we await more data. We received a “nothing found” response on Nektar on 12-Dec-2025, which is inconsistent with earlier responses. Undisclosed SEC investigative activity was confirmed as ongoing six times since Oct-2020, most recently on 27-May-2025\. Abrupt departure of CFO on 01-Jul-2022\. We will appeal this latest response and follow-up as needed. ## Proctor & Gamble Company – PG **Removed from Watch List.** *Repeat of note published 30-Dec-2025* Removed while we await more data. We received a “nothing found” response on P&G on 02-Dec-2025, which is inconsistent with earlier responses. Undisclosed SEC investigative activity previously confirmed as ongoing twice since Mar-2024, most recently on 02-May-2025\. We will appeal this latest response and follow-up as needed. ## SentinelOne, Inc. – S **Removed from Watch List.** Removed while we await more data. We received a “nothing found” response on SentinelOne on 09-Dec-2025, which is inconsistent with earlier responses. Undisclosed SEC investigative activity now confirmed twice since Apr-2024, most recently on 08-May-2025\. Ask if the SEC is investigating matters raised in the Fortis litigation. We will appeal this latest response and follow-up as needed. ## Tutor Perini Corporation – TPC **Removed from Watch List.** Removed while we await more data. We received a “nothing found” response on Tutor Perini on 10-Dec-2025, which is inconsistent with earlier responses. Early signal received on 04-Apr-2024, then confirmed as an ongoing investigation, as of 12-Jun-2024\. Latest signal, dated 06-Jan-2025, suggests an SEC probe is ongoing; not yet confirmed. We will appeal this latest response and follow-up as needed. ***\-- Disclosure Insight®*** *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* *Our Terms of Service, relevant disclosures, and other legal notices can be* [*found here*](http://www.disclosureinsight.com/)*.* ### SEC Investigation Updates: December 30, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-december-c46/ Last updated: 2026-03-17T13:49:03.000Z **All-access clients are welcome to contact us anytime to learn more.** ***Click on the PDF here to access today’s report or read full text below*** [SEC Investigation Updates - December 30, 2025SEC Investigation Updates - December 30, 2025302 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/072f2f80-2be3-49f3-b666-d41c07ce15a6.pdf "Download") ## Company Comments ## AECOM – ACM ***Warning Reiterated.*** **Maintained on DI Watch List.** We’ve been tracking an undisclosed SEC investigation here since Dec-2023, with enforcement proceedings again confirmed as ongoing on 18-Dec-2025\. Four SEC investigations between 2012 and 2023, one was a FCPA matter in 2014. ## EPAM Systems, Inc. – EPAM ***Removed from Watch List.*** Latest signal, dated 27-Aug-2025, suggested an SEC probe was ongoing. However, as of 10-Dec-2025, our work concludes ongoing SEC enforcement proceedings do not appear to directly pertain to EPAM’s conduct, transactions, and/or disclosures. We also know EPAM was involved in an undisclosed cyber investigation that ended for the company on 12-May-2025\. The Trump SEC has shown little interest in pursuing investigations into cyber intrusions. We were tracking this since our Early Signal first received in Oct-2024. ## Optimum Communications, Inc., fka, Altice USA, Inc. – OPTU/ATUS ***Warning Reiterated.*** **Maintained on DI Watch List.** Enforcement proceedings now confirmed as ongoing three times since Nov-2023, most recently on 16-Dec-2025\. **Note**: Altice USA (ATUS) changed its name to Optimum Communications, effective 07-Nov-2025. ## Proctor & Gamble Company – PG **Removed from Watch List.** Removed while we await more data. Undisclosed SEC investigative activity previously confirmed as ongoing twice since Mar-2024, most recently on 02-May-2025\. However, we received a “nothing found” response, on 02-Dec-2025, which is inconsistent with earlier responses. We will appeal this latest response and follow-up as needed. ## Snowflake, Inc. – SNOW ***Removed from Watch List.*** An appeal response dated 21-Dec-2025, suggests undisclosed SEC investigative activity involving this company was over. File(s) remanded for additional processing and potential release of records. We will follow-up if we learn more. No other signs of investigative activity in the SEC’s latest response. Early Signal first received on 16-Oct-2024, was then confirmed as an ongoing investigation on 06-Jan-2025. ## Tradeweb Markets, Inc. – TW ***New Warning.*** Early signal of an undisclosed SEC investigation first received on 21-Apr-2025, and again on 03-Sep-2025\. It was later confirmed as an ongoing SEC investigation on 18-Dec-2025. ***\-- Disclosure Insight®*** [Subscribe now](https://www.disclosureinsight.com/subscribe) *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* *Our Terms of Service, relevant disclosures, and other legal notices can be* [*found here*](http://www.disclosureinsight.com/)*.* ### SEC Investigation Updates - December 29, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-december-608/ Last updated: 2026-03-17T13:49:04.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - December 29, 2025SEC Investigation Updates - NF - December 29, 2025298 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/57c1cf3d-7c47-476b-b1e2-322468addbf9.pdf "Download") [Subscribe](#/portal/signup) ### They Broke the SEC URL: https://www.disclosureinsight.com/they-broke-the-sec/ Last updated: 2025-12-28T18:36:20.000Z ## From John’s Desk … *“Do what you can, with what you have, where you are.”* — Theodore Roosevelt, *Theodore Roosevelt: An Autobiography* (1913) With the solstice behind us and the days finally stretching out again here in the northern hemisphere, I’ve been taking stock of the year we just lived through — and the one we’re about to enter. On December 14th, I alerted you to a 50% decline in undisclosed SEC investigations and noted that the number would continue to fall. The data is clear now: a deeper structural shift is underway inside the agency. Today I want to expand on that earlier note and give you a clear, unvarnished view of what I’m seeing — and how I plan to get you ready for the new year. ### There’s no sugarcoating: It’s bad. After 25 years of watching the SEC up close, it’s clear the agency has been weakened in ways that are structural, deliberate, and increasingly visible in the records and data we’ve obtained under the Freedom of Information Act (FOIA). The rules are still on the books — in some cases stronger than ever — but rules only matter when they’re enforced. And when enforcement credibility erodes, the deterrent effect erodes with it. That’s when fraud risk rises, not because people suddenly become more dishonest, but because the perceived probability of getting caught drops. That’s the dynamic I’m seeing now. > **We’re going to put the administrative state back in its box.** *\- Stephen Miller, White House Deputy Chief of Staff for Policy. Source: Rolling Stone, Inside Stephen Miller’s Reign of Terror, September 15, 2025* Whatever the motivations behind those changes, the practical reality for investors is the same: key enforcement functions have been reduced in priority, if not hollowed out, and the consequences are now working their way into the market. And this isn’t something that snaps back with a change in administration. The weakening of the SEC was targeted, carried out by people who understood the system’s pressure points, and the damage is structural. You don’t rebuild this overnight. Investors, boards, law firms, auditors, and insurance carriers should not assume a quick return to prior norms. > **We want the bureaucrats to be traumatically affected** … When they wake up in the morning, we want them to not want to go to work because they are increasingly viewed as the villains … **We want to put them in trauma.** *\- Russell Vought, Acting Director of the Office of Management and Budget (OMB). Source: Government Executive, ‘Put them in trauma’: Inside a key MAGA leader’s plans for a new Trump agenda, October 28, 2024* ### Regardless of your politics, you need to know what changed at the SEC However you may feel about a weakened SEC, the shifts underway have direct implications for valuation, disclosure quality, enforcement probability, and ultimately your investment decision‑making. As your long‑time and trusted guide through the SEC’s inner workings, I’m putting together a series of short, focused posts you’ll start seeing early in the new year. My goal is simple: give you a clear understanding of what has changed inside the agency and what those changes mean for your risk assessment and investment process. ### A note on integrity of FOIA data In the current environment, some SEC FOIA responses are now using language that makes it harder to understand what’s actually happening. This could lead you to think there is investigative activity where I would not reach that conclusion. The government playing games with FOIA responses isn’t new to me — I sued the SEC for doing this in the past. What matters now is there are far fewer undisclosed investigations than before, which means the ones that remain likely carry higher risk. That makes accurate interpretation more important than ever. Even with all the changes, you can feel confident the DI Watch List stays clean, because I know how to read evolving FOIA replies correctly. ### We could be attacked for this note and its follow-up As I lay out what I’ve learned, it’s entirely possible that Disclosure Insight – and I personally – will face pressure, come under attack, or see attempts to limit access to FOIA‑based information. We’ve discussed this internally, and the conclusion was straightforward: you expect me to call things as I see them without fear, without favor, and without partisanship. That’s the standard I’ve operated under for 25 years, and I’m not changing it now. ### Publishing over the next few weeks: **This week:** SEC Investigation Updates. Several newly closed investigations, along with new ones and updates to ongoing probes. **Early January:** DI Watch List update, covering all companies we’re tracking with confirmed, undisclosed SEC investigations. **January 5 – 18:** The weeks leading into earnings season. A series of short pieces outlining the structural changes I’m seeing inside the SEC and how those shifts will impact your risk assessment going forward. ### Outline for the SEC series: - **The SEC’s quiet retreat from the Foreign Corrupt Practices Act.** - **Accounting and internal controls issues.** - **Whistleblower concerns.** - **Troubling SEC comment letter patterns.** - **Selective case closures.** ### A North Woods Moment **Blizzard conditions in Minnesota today** … but the days are getting longer. This year I spread seeds in my flower beds just as the first snow fell – a dormant‑seeding experiment with native flowers that thrive after exposure to winter cold. I bought a pound of seeds and went wild with them. Can’t wait to see what comes up! Take good care. - *John* > **Service Note:** Access to DI research will become more structured in the new year, with a dedicated tier for readers who want content only and a very limited number of new All‑Access institutional engagements for those who need direct analyst access. If you rely on this work, this is a good moment to stay close. [Subscribe now](https://www.disclosureinsight.com/subscribe) *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* *Our Terms of Service, relevant disclosures, and other legal notices can be* [*found here*](http://www.disclosureinsight.com/)*.* ### Data Shows Far Fewer SEC Investigations Since Inauguration Day URL: https://www.disclosureinsight.com/data-shows-far-fewer-sec-investigations/ Last updated: 2026-03-17T13:49:04.000Z ## From John’s Desk … *“The SEC has increasingly expanded its jurisdiction beyond its statutory mission of investor protection, using enforcement and rulemaking to pursue political objectives. A conservative administration should refocus the Commission on fraud prevention and disclosure, not social policy.”* \- Project 2025, Mandate for Leadership: The Conservative Promise (Heritage Foundation, 2023) [Subscribe now](https://www.disclosureinsight.com/subscribe) ### The FOIA Data are Undeniable Disclosure Insight is now tracking 50% fewer undisclosed SEC investigations than was the case early in the new Trump 47 administration. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/3da768fd-9b9d-41db-8f57-8aca84af833c_975x667-1.png) The above chart shows just how fast this new Trump SEC has been closing its ongoing SEC investigations. From a peak of 119 in April, as of December we are down to only 59 companies with undisclosed SEC investigations recently confirmed as ongoing. For comparison, in November 2020, we were only tracking 64 undisclosed SEC investigations. This was near the end of the Trump 45 administration. Yet here in December 2025, it’s still relatively early in Trump 47\. Our process and volume of FOIA requests have not changed. The results have. Expect this number to continue to fall. In future updates I will brief you on where those investigations have closed and what it means for SEC enforcement priorities going forward. ### The Value of DI Watch List is Even Greater Now In a bit of an unexpected twist, the DI Watch List is now more valuable to your work than under the Biden administration. Let me explain. With far fewer undisclosed SEC investigations today than was the case just seven months ago, those that remain likely carry far higher risk then we might have perceived when the data set was twice its current size. For example, our work found that many of the companies that disclosed cyber intrusions were investigated. That seemed a bit much, but that’s how it was. Barring something unusual, investors rightly do not care much about an SEC investigation into a disclosed cyber intrusion. Most of those cyber investigations are now closed, or in the process of closing. Taking companies like that off the Watch List helped remove low-signal noise from the list. ### The Data has Started Coming In … It is Troubling Finally, the trends I am seeing regarding the regulatory and enforcement priorities of this administration are both troubling and something you will want to know about. Here are some I will speak to in future pieces: - Reduced/changed areas of SEC focus that are likely to hurt investors. - Troubling trends already showing up in SEC comment letters. - Foreign Corrupt Practices Act investigations. - Changes involving whistleblower activity. There are also changes I am seeing that are good for both investors and public companies. I will speak to them as well. That’s it for now. **Drop me a line, would love to know what you think.** – *John* [Subscribe](#/portal/signup) ### Flagstar Bank: 21 Months Later, Allowance for Credit Losses Still Uncertain URL: https://www.disclosureinsight.com/flagstar-bank-21-months-later-allowance/ Last updated: 2026-03-17T13:49:04.000Z #### ***Click here to get a printable PDF of today’s report.*** [DI Report: Flagstar Bank - FLG 2025 1210DI Report: Flagstar Bank - FLG 2025 1210373 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/fc3c52c6-43b1-4dae-ad63-fda774c4c890.pdf "Download") > *“… These ineffective controls impact the Company’s ability to accurately disclose loan rating classifications, identify problem loans, and ultimately recognize the ACL \[Allowances for Credit Losses\] on loans and leases.”* \[clarification added\] \- Flagstar Bank 10-Q filed on 06-Nov-2025 ## Summary & Opinion: With long-running internal controls problems, an undisclosed SEC investigation, and the abrupt departure of an Audit Committee member after just 7 months, Flagstar is an extend-and-pretend risk now. ### Key Points: - **Undisclosed SEC Investigation** - **Festering Internal Controls Problems** - **Abrupt Departure of an Audit Committee Member** - **Public Finger Pointing Over Internal Controls** **Key Players:** The three individuals central to our negative Flagstar thesis previously worked together at senior levels in the Trump 45 administration. After leaving government, all three became involved with Flagstar. This report expresses no view on any of them, or their politics. **Steven Mnuchin:** Treasury Secretary (2017–2021) under Trump 45\. Founded Liberty Strategic Capital. A group led by Liberty reported holding 24.9% of Flagstar in a 13D filed 17‑Oct‑2025\. He is Flagstar’s Lead Independent Director. B**rian Callanan:** This is the Audit Committee member who left Flagstar. General Counsel at US Treasury (2019-2021) under Trump 45\. He later joined Mnuchin’s Liberty Strategic Capital as General Counsel. Appointed to Flagstar’s board in Dec-2024, and later to his role on the Audit/Risk committees around Apr-2025\. He resigned Thursday, 30-Oct-2025, effective that Sunday, 02-Nov-2025\. He was in the role for only 7 months. Details below. **Joseph Otting:** Comptroller of the Currency (2017–May 2020) under Trump 45\. Appointed President/CEO of New York Community Bancorp/Flagstar Bank, effective 01-Apr-2024 and later Executive Chair on 05-Jun-2024, joining amid internal controls problems “related to internal loan review.” In our opinion, public blame‑shifting over those weaknesses now tarnishes his leadership. Details below. [Subscribe now](https://www.disclosureinsight.com/subscribe) ## The Undisclosed SEC Investigation Since Sep-2024, we have been tracking an undisclosed SEC investigation at the former New York Community Bank. After a merger and a few name changes, it is now known as Flagstar Bank, NA, ticker FLG. This investigation was last confirmed as ongoing at the former NYCB, now Flagstar, as of 10-Sep-2025. DI now tracks half as many undisclosed SEC investigations as we did earlier in 2025, when Trump first returned. Most were terminated – Flagstar’s remains open. Not good. ## Festering Internal Controls Problems On 29-Feb-2024, Flagstar first disclosed internal controls were not effective as of 31-Dec-2023\. Per that 8-K/A, the weakness “related to internal loan review, resulting from ineffective oversight, risk assessment and monitoring activities.” At a bank. Experts were hired, remediation efforts undertaken, disclosure language evolved. Yet, the 10-Q filed 06-Nov-2025, confirms internal controls were still not effective as of 30-Sep-2025. **DI’s Take:** Loans are a bank’s core assets – It’s how they make money. Flagstar’s Q3-2025 10-Q shows Flagstar has loans/assets of 69%, or $62.7 billion in loans. Yet for 21 months since 31-Dec-2023, “material weaknesses” in “internal loan review” and “credit loss evaluation” persist. Worse, even after the passing of 21 months since Dec-2023, Flagstar says it still can’t “ultimately recognize the ACL \[Allowance for Credit Losses\] on loans and leases.” For real. That is, investors don’t know if Flagstar’s stated $63 billion of loans are truly worth $63 billion, or if it’s hiding billions in losses. That’s dangerous in any macro environment, more so today. Could you run your portfolio like this? ## Abrupt Departure of an Audit Committee Member Brian Callanan was General Counsel at Mnuchin’s Liberty Strategic Capital when appointed to Flagstar’s board in mid‑December 2024\. The related 8-K explicitly said he, “was not appointed to serve on any committee of the Board of Directors in connection with his appointment as a director.” However, the Apr-2025 proxy statement revealed he’d been placed on Flagstar’s Audit and Risk Assessment Committees. While not a qualified financial expert, Liberty’s general counsel was given access to Flagstar’s most sensitive internal controls data. Callanan resigned from Flagstar’s board 7 months later. Flagstar disclosed this 03-Nov-2025\. Notably, two weeks earlier, TD Bank (TD) had put out a press release, on 16-Oct-2025, announcing he was leaving Liberty to join TD as its US General Counsel (effective 01-Dec-2025). **From the Flagstar Bank 8-K filed on 03-Nov-2025** > On October 30, 2025, Brian R. Callanan notified Flagstar Bank, N.A. (the “Bank”), of his resignation as a member of the Board of Directors of the Bank, effective November 2, 2025\. Such decision was not the result, in whole or in part, of any disagreement with the Bank on any matters relating to the Bank’s operations, policies or practices. **DI’s Take on the 8-K:** We see no mention of his Audit/Risk committee roles while on the board. We had to look it up. The 8-K was also silent on Callanan’s ties to Liberty. More troubling is how quickly Callanan went for the exit of Flagstar. He resigned on Thursday, 30-Oct-2025, with an effective date that Sunday, 02-November – days before the next 10-Q was due. Both Flagstar and Liberty had time to put together a smooth transition announcement. They chose not to. Instead, they let Callanan stay in his Audit Committee role at Flagstar until what appeared to be the last moment before he’d have to sign off on Flagstar’s latest 10-Q. Also consider that Callanan may have also left a lot of money on the table by leaving Liberty when he did. Finally, we note the Liberty investor group owns 24.9% of Flagstar stock, below the 25% regulatory control threshold. Yet Mnuchin’s Lead Independent Director role and Callanan’s Liberty GC background raise questions about board independence. ## Public Finger Pointing Over Internal Controls The Flagstar Mar-2024 10-K contains unusual language that caught our attention. The disclosures had escalated into actual finger-pointing at the board – something as unusual as it is unsettling. **From the 10-K filed on 14-Mar-2024:** > ***Our Board of Directors did not exercise sufficient oversight responsibilities.*** As a reminder, Joseph Otting became CEO effective 01-Apr-2024 (announced 08-Mar-2024). This was after the above disclosure was made. From the outside, we cannot say what, if any, influence he had on the above disclosure. But Otting was fully in charge when the language changed, in Aug-2025\. By this point, he was both Chairman and CEO. **From the 10-Q filed on 07-Aug-2025:** > ***… the Board of Directors were not able to exercise sufficient oversight.*** By Aug-2025, the board, of which Otting is chairman, is no longer blamed for the internal controls shortfall. The company is at fault now; of which he is CEO. That is, the corporation Otting runs failed to enable the board he chairs to exercise sufficient oversight. **DI’s Take:** Rarely do disclosures assign blame for a controls problem so directly to the board — a clear governance breakdown. Combining Chairman and CEO roles magnified Otting’s exposure and tarnishes his tenure. Prolonged control failures may mask deeper loan‑book problems. The disclosure shift from board to company-level blame coincides with Liberty’s board representation (two seats). These people aren’t dumb bunnies — investors should think hard about what’s really going on. ***– John P. Gavin, CFA, NACD.DC*** **See Addendum Below** [Subscribe now](https://www.disclosureinsight.com/subscribe) # Addendum **Internal Controls Problems Related to Loans** In an 8-K/A, filed 29-Feb-2024, Flagstar first disclosed Internal controls were not effective, as of 31-Dec-2023. Per that 8-K, the internal controls problem, “related to internal loan review, resulting from ineffective oversight, risk assessment and monitoring activities.” That same day, 29-Feb-2024, Flagstar’s 10-K was delayed over an array of accounting adjustments. The internal controls warning was repeated. Since this first disclosure, the warnings about material weaknesses in internal controls have been repeated, most recently with the filing of the 10-Q for the quarter ended 30-Sep-2025, filed on 06-Nov-2025. **Flagstar Bank 10-Q filed on 06-Nov-2025:** *Management concluded its disclosure controls and procedures were not effective as of September 30, 2025 ...* *… These ineffective controls impact the Company’s ability to accurately disclose loan rating classifications, identify problem loans, and ultimately recognize the ACL \[Allowances for Credit Losses\] on loans and leases.* Evaluation of Disclosure Controls and Procedures Under the supervision of our Chief Executive Officer and Chief Financial Officer, Management evaluated the effectiveness of design and operation of our disclosure controls and procedures pursuant to Rule 13a-15(b), as adopted by the SEC under the Securities Exchange Act of 1934, as amended (the “Exchange Act”). Management concluded its disclosure controls and procedures were not effective as of September 30, 2025, due to the material weaknesses in its system of Internal Control over Financial Reporting, as described below. Notwithstanding the material weaknesses, Management evaluated its disclosure controls and procedures, and concluded the financial statements included in this report fairly present, in all material respects, Flagstar’s financial position, results of operations, capital position, and cash flows, for the periods presented, in conformity with GAAP. Per Rules 13a-15(e) and 15d-15(e), disclosure controls and procedures are the controls and other procedures designed to ensure information required to be disclosed in the reports Flagstar files or submits under the Exchange Act is recorded, processed, summarized, and reported within the time periods specified in the SEC’s rules and forms. Disclosure controls and procedures include activities designed to ensure information required to be disclosed in the reports that Flagstar files or submits under the Exchange Act is accumulated and communicated to management, including the Chief Executive Officer and Chief Financial Officer, to allow timely decisions regarding required disclosure. Material Weaknesses in Internal Control over Financial Reporting A material weakness is a deficiency, or combination of deficiencies, in Internal Control over Financial Reporting, such that there exists a reasonable possibility a material misstatement in the annual or interim financial statements may not be prevented or detected on a timely basis. Management has previously identified the following material weaknesses in its system of Internal Control over Financial Reporting. Risk assessment: We lacked effective periodic risk assessment processes to identify and timely respond to emerging risks in certain financial reporting processes and related internal controls, including independent Credit Review, that were responsive to changes in the business operations and regulatory and economic environments in which Flagstar operates. Monitoring: Our recurring monitoring activities over process level control activities, including independent Credit Review, were not operating effectively. Control activities: We did not sufficiently maintain effective control activities related to independent Credit Review processes and certain loan data reconciliations. Specifically, our independent Credit Review process controls were ineffective as Flagstar lacked the consistent application of an appropriate framework to validate that the ratings were accurate, timely, and appropriately challenged. These ineffective controls impact the Company’s ability to accurately disclose loan rating classifications, identify problem loans, and ultimately recognize the ACL on loans and leases. As a result of these ineffective risk assessment, monitoring, and control activities, the Board of Directors were not able to exercise sufficient oversight. These control deficiencies create a reasonable possibility that a material misstatement to the condensed consolidated financial statements may not be prevented or detected on a timely basis, and therefore we concluded that the deficiencies represent material weaknesses in our Internal Control over Financial Reporting. Remediation Status of Reported Material Weaknesses In early 2024, we appointed several new members to the Board of Directors with extensive experience as financial experts in our industry and backgrounds in risk management, including a new Lead Independent Director, a new Chairman of the Audit Committee and a new Chairman of the Risk Assessment Committee. The frequency of Audit Committee meetings increased substantially during 2024, with both Audit and Risk Assessment Committees dedicating sessions to evaluating credit risk in the portfolio. In addition, during 2025, we have added a combined joint session of the Risk Assessment Committee and the Audit Committee that occurs at least quarterly to discuss our ACL methodology and results. Management has identified and has implemented, the following actions to address the material weakness in our risk assessment processes: •Appointed a Chief Risk Officer, a Chief Credit Officer and a new Senior Director of Credit Review, all with large commercial bank credit experience. •Enhanced the depth and breadth of our Independent Credit Review program to make the necessary changes in scoping approach, risk assessment and related processes, and elevating the overall stature of the Independent Credit Review function. We have improved the experience-level of the personnel performing credit reviews. Management has taken the following actions to address the material weakness in our monitoring activities: •Increased the frequency and nature of reporting from our Independent Credit Review function and First-Line Business Units to the Board’s Risk Assessment Committee in support of the Boards’ risk oversight Management has identified and has implemented the following actions to address the material weakness in our control activities: •Expanded the use of independent credit analysis and reduced our reliance on tools and analyses prepared by First-line Business Units. •Increased the Credit Review team’s ability and elevated its stature within the organization to independently challenge risk rating methodologies and results. •Assessed the adequacy of staffing and resource levels and expertise within the Independent Credit Review function, considering the size, complexity, and risk profile of the loan portfolios. Management has enhanced the expertise and capacity of the Independent Credit Review function. •Provided comprehensive risk rating process training to all employees involved in the lending and credit review processes. •Enhanced processes to identify and assess risks associated with estimating the ACL and improving data governance processes. •Increased credit review coverage of the portfolio. Approximately 700 borrowers representing $21.9 billion of loan balances were tested during the nine months ended September 30, 2025. We continue to actively work to remediate the material weaknesses described above and are primarily in the sustainability and validation testing phase of remediation. We continue to assess our progress and whether any additional remediation steps or additional measures are needed to remediate the underlying causes of the material weaknesses, including the governance and oversight of our system of Internal Control over Financial Reporting. While we believe our actions will be effective in remediating the material weaknesses, the material weaknesses will not be remediated until the remediation efforts we have taken are deemed to be sufficient through evidence of sustainability and Management concludes the remedial efforts are effective based upon validation testing. Changes in Internal Control over Financial Reporting Except for the actions noted above related to remediation of our material weaknesses, there have been no changes in our system of Internal Control over Financial Reporting (as such term is defined in Rules 13a-15(f) and 15d-15(f) under the Exchange Act) during the three months ended September 30, 2025 to which this report relates, which materially affect, or are reasonably likely to materially affect, our system of Internal Control over Financial Reporting. ### SEC Investigation Updates - December 04, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-december/ Last updated: 2026-03-17T13:49:04.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - December 04, 2025SEC Investigation Updates - NF - December 04, 2025320 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/ad6f6143-c846-4c6b-be71-f2db8fae1059.pdf "Download") [Subscribe](#/portal/signup) ### Virtu Financial: Waiting for the Shutdown to End URL: https://www.disclosureinsight.com/virtu-financial-waiting-for-the-shutdown-3/ Last updated: 2025-11-11T03:39:35.000Z **Virtu Financial, Inc. – VIRT $35.95 Mkt Cap: $5.5 B** ### From the Virtu Financial, Inc. 10-K filed on 17-Feb-2023: ***Initial disclosure of SEC investigation*** > Legal and Regulatory Proceedings > > In the ordinary course of business, the nature of the Company’s business subjects it to claims, lawsuits, regulatory examinations or investigations and other proceedings, any of which could result in the imposition of fines, penalties or other sanctions against the Company. The Company and its subsidiaries are subject to several of these matters at the present time, including, among others, a matter in which t**he Company has been responding to requests for information from the U.S. Securities and Exchange Commission in connection with an investigation of aspects of the Company’s information access barriers.** The Company is cooperating with this civil investigation. ### From the Virtu Financial, Inc. 10-Q filed on 31-Jul-2025: > **In June 2025, the Company reached an agreement in principle to settle the matter with the SEC’s Enforcement Staff.** The terms of the anticipated settlement, which is subject to SEC Commission approval and certain other conditions, are not expected to have a material impact on the Company or its business. **The Company anticipates that the agreement will be finalized during the third quarter of 2025\.** The parties jointly sought and obtained a 60-day stay of proceedings from the District Court in connection with the finalization of the settlement. ### From the Virtu Financial, Inc. 10-Q filed on 30-Oct-2025: > In June 2025, the Company reached an agreement in principle to settle the matter with the SEC’s Enforcement Staff. The terms of the anticipated settlement, which is subject to SEC Commission approval and certain other conditions, are not expected to have a material impact on the Company or its business. **The Company anticipates that the agreement will be finalized following the reopening of the federal government.** The parties previously jointly sought and obtained a stay of proceedings in connection with the finalization of the settlement which remains in effect. #### *The remaining exposure* > **In matters related to the SEC investigation noted above, the Company and certain of its current and former executive officers were named as defendants** on May 19, 2023 in Hiebert v. Virtu Financial, Inc., No. 23-cv-03770 and on October 31, 2023 in City of Birmingham Retirement and Relief System v. Virtu Financial, Inc., No. 23-cv-08123\. The complaints were each filed by purported stockholders in the Eastern District of New York on behalf of a putative class and assert that the Company made materially false and misleading statements and omissions in its public filings in violation of federal securities laws. The complaints were subsequently consolidated and recaptioned in re Virtu Financial, Inc. Securities Litigation, No. 23-cv-03770\. The Company believes it has meritorious defenses against claims that its public disclosures were inadequate or misleading. The Company maintains that such disclosures were true and accurate and compliant with applicable law and is defending itself vigorously. The Company also has received requests for information related to the SEC investigation pursuant to Section 220 of the Delaware General Corporation Law from counsel for purported stockholders. **On March 26, 2025, members of the Company’s Board of Directors and certain current and former executives were named in a derivative complaint** in Adams v. Viola et al., No. 1:25-cv-1688 filed on behalf of the Company in the Eastern District of New York in which it is asserted that the defendants breached fiduciary duties to the Company related to the FS matter. A similar derivative complaint was filed on April 9, 2025 in Deisz v. Viola et al., 25-CV-1958 in the Eastern District of New York against current and former members of the Board of Directors and executives. The derivative complaints were subsequently consolidated and recaptioned In re Virtu Financial Inc. Derivative Litigation. The defendants deny that they breached any fiduciary duties related to the FS matter and are defending themselves vigorously. [Subscribe](#/portal/signup) ### 3D Systems (DDD): Small Company, Big Festering Problems URL: https://www.disclosureinsight.com/3d-systems-ddd-small-company-big/ Last updated: 2026-03-17T13:49:04.000Z ### 3D Systems (DDD): $2.61 $336 mm Mkt Cap ### Summary and Opinion If we were advising the board of 3D Systems, we’d suggest they call for meaningful focus on improving disclosure quality and addressing lingering accounting issues at the company. - **There is no excuse for internal controls problems to go unresolved for almost 5 years now. Fix it.** - **Tell your management and lawyers to stop playing Disclosure Games about what’s behind 3D’s long-running SEC investigation.** As written, and since first disclosed in Aug-2022, DDD requires investors to go look up an unidentified a court case from years ago to try to find out what the SEC has been investigating since at least then. Your average investor doesn’t have easy access to the resources needed to do that. Most will just give up and move on to another company. This is a shoddy disclosure practice. Failing the above, we see no reason for investors to take the risk of owning these shares at this time. ### An Array of Festering Problems - **You still can’t figure out what the SEC has been investigating since 2021.** - **Internal controls weakness, dating back to Dec-2020**. - **CFO left on short notice, Oct-2023.** - **New Auditor, Dec-2023.** - **Replacement CFO also left on short notice, Sep-2025.** Below we show the shoddy disclosures from 3D Systems about an SEC probe we were tracking since Sep-2021, but not disclosed until Aug-2022. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/67d24afb-74de-4583-b1e1-b0e63383ffe0_1076x169.png) ### From the recent 10-Q filed on 04-Nov-2025: > "… our disclosure controls and procedures were not effective as of September 30, 2025 due to the material weaknesses discussed in our 2024 Annual Report on Form 10-K. \[*DI Note: This has been the case since Dec-2020*\] #### SEC Investigation > **On April 15, 2022, the Company was informed that the SEC is conducting a formal investigation of the Company related to, among other things, allegations that had been brought against the Company in a securities class action lawsuit that was brought against the Company in 2021 and settled in January 2024**. The Company has subsequently received subpoenas from the SEC for the production of documents and information related to its investigation as a follow on to a previous voluntary request for documents. The most recent SEC subpoena was received by the Company in August 2024, and requested additional documents and information relating to its continuing investigation of the Company. The Company completed its submission of this additional information to the SEC by the end of November 2024\. The Company is continuing to cooperate with the SEC in connection with its formal investigation. ### Developments of Note: - **10-Q filed on 09-Nov-2022:** Internal controls not effective. - **8-K filed on 21-Sep-2023:** CFO resigns, effective 15-Oct-2023. - **8-K filed on 06-Dec-2023:** Changes in Registrants Certifying Accountant. - **8-K filed on 14-Dec-2023:** New CFO. - **8-K filed on 11-Jan-2024:** Legal counsel leaving effective, effective 3-Apr-2024. - **NT 10-K filed on 29-Feb-2024:** 10-K delayed. - **8-K filed on 11-Mar-2024:** Can’t file 10-K within 15-day extension period. - **8-K filed on 22-Mar-2024:** NYSE Delisting notice. - **NT 10-Q filed on 13-May-2024:** 10-Q delayed. - **NT 10-Q filed on 09-Aug-2024:** 10-Q delayed. - **10-K filed on 13-Aug-2024** (For FY 2023). - **10-Q filed on 20-Aug-2024** (For Q1-2024). - **10-Q filed on 29-Aug-2024:** Internal controls not effective. - **NT 10-Q filed on 13-Aug-2024:** 10-Q delayed. - **8-K filed on 22-Nov-2024:** NYSE Delisting notice. - **NT 10-K filed on 17-Mar-2025:** 10-K delayed. - **10-K filed on 27-Mar-2025:** Internal controls not effective. - **10-Q filed on 12-May-2025:** Internal controls not effective. - **10-Q filed on 11-Aug-2025:** Internal controls not effective. - **8-K filed on 18-Aug-2025:** **CFO resigned on short notice,** on 12-Aug-2025, effective one month later. He started in Dec-2023\. Just 20 months there. - **8-K filed on 20-Aug-2025:** **CFO leaving sooner than expected.** Was expected to be effective 12-Sep-2025\. Interim CFO appointed effective 29-Aug-2025. - **10-Q filed on 04-Nov-2025:** Internal controls not effective. [Subscribe now](https://www.disclosureinsight.com/subscribe) ### SEC Investigation Updates: October 29, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-october-355/ Last updated: 2026-03-17T13:49:05.000Z **All-access clients are welcome to contact us anytime to learn more.** ***Click on the PDF here to access today’s report or read full text below*** [SEC Investigation Updates - October 29, 2025SEC Investigation Updates - October 29, 2025305 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/06967e43-51fe-437c-bd81-82ea3dd3f271.pdf "Download") ## Company Comments ### AstraZeneca PLC – AZN ***Warning Reiterated*** **Maintained on DI Watch List.** We’ve been tracking an undisclosed SEC investigation here since Dec-2023, with enforcement proceedings again confirmed as ongoing on 02-Sep-2025\. AZN appears to be a FCPA frequent flyer, going back to 2010\. No clear disclosure of SEC investigative activity found since the 20-F filed on 21-Feb-2023, at which time AZN referred to having fully resolved a FCPA investigation with the SEC in Jul-2020. **DI’s Take**: As the Trump 47 SEC has reduced its focus on FCPA cases, this suggests AZN may be dealing with something unrelated. ### Bank of America Corporation – BAC ***New Warning*** **Added to Watch List.** Early signal of an undisclosed SEC investigation first received on 23-Jul-2025, later confirmed as an ongoing SEC investigation on 16-Sep-2025\. A separate, undisclosed investigation ended in Mar-2025\. We know nothing further on that matter. ### Citigroup, Inc. – C ***New Warning*** **Added to Watch List.** Early signal of an undisclosed SEC investigation first received on 12-Jun-2025, later confirmed as an ongoing SEC investigation on 08-Sep-2025\. We have documents from a 2024 SEC investigation into SPAC underwriters. ### KeyCorp – KEY ***Disclosed SEC Investigation Ends*** **New data** confirms KeyCorp’s claims an SEC probe into off-channel communications is over, as cited below. However, as of 08-Sep-2025, the company remains in a post-settlement compliance period which could go against them if they violate a related settlement agreement. No other signs of ongoing SEC investigative activity found. Per the KeyCorp 10-K filed on 22-Feb-2024: For example, on February 9, 2024, affiliates of Key entered into a settlement agreement with the SEC’s Division of Enforcement to resolve an investigation of the affiliates’ compliance with records preservation requirements related to business communications sent over off-channel electronic messaging platforms. ### Novo Nordisk A/S – NVO ***Removed from Watch List.*** **Undisclosed SEC Investigation ends.** Recently released documents tell us it was a FCPA probe, from Dec-2023 to Aug-2025, largely focused on Saudi Arabia. We were tracking this since Jul-2024. We find no signs of a post-settlement compliance period, which is otherwise common in FCPA matters. This is consistent with the Trump 47 SEC having recently lost interest in pursuing FCPA investigations. ### Tesla, Inc. – TSLA ***Warning Reiterated*** **We now know Tesla had not one, but two undisclosed SEC investigations**; one recently ended. The other one was recently confirmed as ongoing, as of 26-Sep-2025. An SEC investigation into Musk’s claims about Tesla autopilot, as first reported by Reuters in May-2024, could be the one that closed. We’re trying to get the related records. We have no idea what the other open investigation is about. ### Twitter, Inc. – TWTR ***Removed from Watch List.*** Latest signal, dated 15-May-2025, suggested an SEC probe was ongoing. However, an appeal response, dated 02-Sep-2025, now suggests SEC investigative activity involving the former Twitter is over. The SEC not once, not twice even – but three times – asked about Twitter’s user metrics in three different investigations since late 2015\. It also raised questions about user metrics in comment letters sent to the company three times between 2013-2017. Our work confirmed ongoing, and undisclosed SEC investigative activity seven times since May-2019\. We will not be surprised if we later learn this now-closed investigation was also about user metrics. ***\-- Disclosure Insight®*** [Subscribe](#/portal/signup) *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* *Our Terms of Service, relevant disclosures, and other legal notices can be* [*found here*](http://www.disclosureinsight.com/)*.* ### SEC Investigation Updates: October 27, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-october-a3a/ Last updated: 2026-03-17T13:49:05.000Z ***Click on the PDF here to access today’s report -*** [SEC Investigation Updates - October 27, 2025SEC Investigation Updates - October 27, 2025291 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/89f4334e-b920-404c-99fb-123cfd38c6f9.pdf "Download") **All-access clients are welcome to contact us anytime to learn more.** [Subscribe](#/portal/signup) *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* *Our Terms of Service, relevant disclosures, and other legal notices can be* [*found here*](http://www.disclosureinsight.com/)*.* ### DI's Early Signals Report: October 22, 2025 URL: https://www.disclosureinsight.com/dis-early-signals-report-october/ Last updated: 2026-03-17T13:49:05.000Z ***Click on the PDF here to access a printable version of this report.*** [DI's Early Signals Report: October 22, 2025DI's Early Signals Report: October 22, 2025298 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/f63e7294-37e7-4282-87d0-252a68d5bc81.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What’s an Early Signal? **DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity**. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation as “confirmed” after we file an administrative appeal and have received a response that says as much. **Important**: **The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security**. In its responses, the SEC did not disclose the details on investigative activity referenced herein. They may pertain to the conduct, transactions, and/or disclosures of the companies; but that is not yet confirmed. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. At this point, we believe the investigation does pertain to the conduct, transactions, and/or disclosures of the companies. 2. There is an investigation in the present day in which enforcement proceedings remain ongoing, however, they only relate to the company. An example is when a company gets caught up is a larger multi-company investigation that remains ongoing, but the company is no longer directly involved. 3. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 4. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 5. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. **All-access clients are welcome to contact us anytime to learn more.** [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### SEC Investigation Updates - October 15, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-october-bf2/ Last updated: 2026-03-17T13:49:05.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - October 15, 2025SEC Investigation Updates - NF - October 15, 2025313 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/958de188-aea3-4b06-8095-12746ace87b5.pdf "Download") [Subscribe](#/portal/signup) ### SEC Investigation Updates: October 11, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-october-f12/ Last updated: 2026-03-17T13:49:07.000Z ### Exxon Mobil Corporation – XOM ***Removed from Watch List*** **Undisclosed SEC investigation ends.** We now know of at least four SEC probes of Exxon since Jul-2012\. One was a FCPA investigation that ended in Jul-2020\. However, a response dated 04-Sep-2025, gives us reason to believe there are no ongoing investigations of Exxon. ### Interpublic Group of Companies, Inc. – IPG ***Removed from Watch List*** **Undisclosed SEC investigation ends;** we have some of the records. This was a FCPA investigation involving business relationships with a list of Chinese entities. It started in May-2024 and ended almost a year later, in Mar-2025\. We were tracking this since our Early Signal first received in Aug-2024. Document excerpt here – ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/3b0b516a-d943-408e-9cf4-f41828b94afe_1050x894.png) ### Lennar Corp. – LEN ***Removed from Watch List*** **Undisclosed SEC investigation ends;** we have some of the records. This was an investigation into a Jul-2023 cyber incident that ended in Mar-2025\. We’re not surprised it ended. It was almost two years old. Further, this new Trump SEC has shown little interest in pursuing investigations into cyber intrusions. We were tracking this since our Early Signal first received in Jun-2024. ### NuCor Corp. – NUE ***Removed from Watch List*** **Undisclosed SEC investigation ends;** we have some of the records. This was an investigation going back to as least May 2023, largely focused on all Honduras mining projects of the company. It ended in May-2025\. We were tracking this since our Early Signal first received in Nov-2024\. The documents we received are analytically rich. ### NuScale Power Corp – SMR ***Investigative Records Released*** **Undisclosed SEC investigation ends;** we have some of the records. This investigation was titled, “In the Matter of Certain Employment and Separation Agreements.” **You don’t want to see one of these investigations at a company.** They signal the SEC had concern about possible violations of an SEC rule where the company could have potentially used employment/consulting agreements or releases to deter people from communicating directly with the SEC about potential securities law violations. As can be seen below, NuScale’s involvement in this investigation ended in Mar-2025. Document excerpt here – ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/0ed0ece1-913e-4f3d-8839-1321f42fc7e2_1050x885.png) ### Prospect Capital Corp. – PSEC ***Removed from Watch List*** **Undisclosed SEC investigation ends;** we have some of the records – including copies of four subpoenas. They are analytically rich and reveal, in detail, that Prospect kept investors in the dark on an in-depth, formal SEC investigation of its investment advisor, Prospect Capital Management, L.P. It just ended in May-2025\. We were tracking this since our Early Signal first received in Nov-2024\. The research history includes an internal controls shortfall in 2022-2023\. Worth noting: Prospect Capital misled investors about SEC investigative activity and attacked our warnings about the same in 2015\. Same CEO there today. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/2bd1c294-a7b0-4c64-a525-6b63406c203b_1050x755.png) ### Salesforce, Inc. – CRM ***Removed from Watch List*** **Undisclosed SEC investigation ends;** we have some of the records. They are analytically rich and reveal Salesforce kept investors in the dark on a meaningful investigation. Running from 2023 to 2025, this formal SEC investigation focused heavily on Salesforce’s “Genie” and “Data Cloud” product. As a reminder, Salesforce launched Genie in September 2022 as a real-time data platform, later renamed Data Cloud. Its debut was clouded by internal controversy, including a lawsuit from a former executive who alleged the platform lacked true real-time capabilities. He claims he was retaliated against for raising concerns. We were tracking this since our Early Signal first received in May-2024. ### SL Green Realty Corporation – SLG ***Removed from Watch List*** **Undisclosed SEC investigation ends.** In Sep-2025, we learned an undisclosed SEC investigation we first found at SL Green on 12-Aug-2024, was over. We only have two pages of records from this matter, neither of which tell us much except that it ended in Sep-2024\. Other than this being the first sign of an SEC probe we found since we started covering SL Green Realty in May-2016, nothing notable in the research history here. ### Southwest Airlines Co. – LUV ***Removed from Watch List*** **Undisclosed SEC investigation ends;** we have some of the records. This was an investigation into massive flight cancellations in Dec-2022 due to Winter Storm Elliott. An 8-K at the time disclosed that Southwest estimated it lost $400 to $425 million in revenue from this disruption. Our work suggests Southwest may have known about this latest SEC probe since at least Jul-2023\. It ended in Sep-2024\. We got the related documents in Sep-2025. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/6d04c871-35bb-4995-8988-625594f36d4b_1050x922.png) ### Summit Hotel Properties, Inc. – INN ***Removed from Watch List*** **Undisclosed SEC investigation ends;** we have some of the records. This investigation was titled, “In the Matter of Certain Employment and Separation Agreements.” **You don’t want to see one of these investigations at a company.** They signal the SEC had concern about possible violations of an SEC rule where the company could have potentially used employment/consulting agreements or releases to deter people from communicating directly with the SEC about potential securities law violations. We were tracking this since our Early Signal first received in Aug-2024\. Summit’s involvement in this investigation ended in Mar-2025\. Here’s the documents the SEC requested from the company in a subpoena sent in Nov-2023 – Document excerpt here – ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/7d066c6c-a459-4f89-83a0-5d5940030d67_1050x574.png) ### Viatris, Inc. – VTRS ***Removed from Watch List*** **Undisclosed SEC investigation ends;** we have some of the records. It appears this was a FCPA investigation involving business relationships in Croatia, Bosnia, and Herzegovina. We know it was active in 2024, but don’t know when it ended. We were tracking this since the Early Signal first received in Sep-2023\. This was shortly before a new CFO was announced in Dec-2023. Document excerpt here – ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/7dbee32b-88b5-40fe-bac0-d02867a278d9_1050x907.png) ***\-- Disclosure Insight®*** [Subscribe](#/portal/signup) *Disclosure Insight research provides data, commentary, and analysis on public company interactions with investors and with the SEC. Our work is heavily reliant on company disclosures and our expertise in using the Freedom of Information Act.* *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* ### SEC Investigation Updates: October 08, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-october-2f2/ Last updated: 2026-03-17T13:49:08.000Z - **Agios Pharmaceuticals, Inc. - AGIO ($40.87 $2.4 B mkt cap)** - **Arista Networks, Inc. - ANET ($145.29 $182 B mkt cap)** - **Armour Residential REIT, Inc. - ARR ($15.59 $1.8 B mkt cap)** - **Diebold Nixdorf, Inc. - DBD ($57.33 $2.1 B mkt cap)** - **Elbit Systems Ltd. - ESLT ($520.50 $23.6 mkt cap)** ### Agios Pharmaceuticals, Inc. – AGIO ***Removed from Watch List*** **Undisclosed SEC investigation ends**, we have some of the records. This investigation was titled, *“In the Matter of Certain Employment and Separation Agreements.”* Document excerpt here - ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/f05a57c6-65ca-46e7-93d9-4ecf502deb1e_776x637-1.png) **You don’t want to see one of these investigations at a company.** It tells us there was an SEC probe into possible violations of a rule where a company may have used employment or consulting agreements — or releases — to discourage individuals from communicating directly with the SEC about potential securities law violations. **The timing of this investigation is notable, if not troubling.** It began in Aug-2023 and concluded in Mar-2025\. That start date came just after the Audit Committee Chair declined to stand for reelection in Apr-2023\. Another Audit Committee member also departed abruptly, effective May-2023. Makes you wonder: were one or both of those Audit Committee members the SEC’s tipsters? [Subscribe now](https://www.disclosureinsight.com/subscribe) ### Arista Networks, Inc. – ANET ***Removed from Watch List*** **Undisclosed SEC investigation ends.** On 24-Sep-2025, we learned an undisclosed SEC investigation we first found at Arista Networks on 27-Aug-2024, appeared to be over. The investigative file was remanded for further processing. In the history we earlier noted the abrupt departure of the general counsel, effective 07-May-2025, with no explanation given. ### Armour Residential REIT, Inc. – ARR ***Removed from Watch List*** **Undisclosed SEC investigation ends**, we have some of the records. Primarily focused on Armour’s relationship with Armour Capital Management, the documents we obtained are from May-2024 to Jul-2025\. An excerpt is cited below. **We previously found a wide array of accounting-related problems here,** including an internal investigation that lasted less than a month in 2024 (it was part of the SEC’s investigation); controls problems; 10-K delayed in Mar-2024; CFO transition; and retirement of co-CEO. Document excerpt here - ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/df9233ff-5a1a-4392-8e26-0b6f2723ea1c_553x639.png) ### Diebold Nixdorf, Inc. – DBD ***Removed from Watch List*** **Undisclosed SEC investigation ends**, we have some of the records. They show this was a Foreign Corrupt Practices Act (FCPA) investigation involving a Diebold distributor in Saudi Arabia. **What’s notable, and even positive for Diebold, is how fast it ended** – only six months after it started. Records we obtained show it started in Feb-2024 and ended in Nov-2024\. Most take much longer. We’ve seen FCPA probes last for 10 years. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/9adb255b-0a81-4cfd-997c-76b482a65957_756x436.png) ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/1310653c-36e1-4cfe-bc71-92d9242177d8_726x675.png) ### Elbit Systems Ltd – ESLT ***Removed from Watch List*** **Undisclosed SEC investigation ends.** In Aug-2025, we learned an undisclosed SEC investigation we first found at Elbit Systems on 22-Oct-2024, was over. We know of about 50 pages of related records which we are trying to obtain. Nothing notable in the research history here. [Subscribe](#/portal/signup) *Disclosure Insight research provides data, commentary, and analysis on public company interactions with investors and with the SEC. Our work is heavily reliant on company disclosures and our expertise in using the Freedom of Information Act.* *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* ### SEC Investigation Updates: October 06, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-october/ Last updated: 2026-03-17T13:49:08.000Z ***Click on the PDF here to access today’s report*** [SEC Investigation Updates - October 06, 2025SEC Investigation Updates - October 06, 2025291 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/fd3109f7-3030-4c07-a6e7-b15308991891.pdf "Download") **All-access clients are welcome to contact us anytime to learn more.** [Subscribe](#/portal/signup) *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* *Our Terms of Service, relevant disclosures, and other legal notices can be* [*found here*](http://www.disclosureinsight.com/)*.* ### Government Shutdown Disrupts SEC Operations URL: https://www.disclosureinsight.com/government-shutdown-disrupts-sec/ Last updated: 2025-10-01T15:58:03.000Z **Another government shutdown?** Here’s how it impacts the Securities and Exchange Commission (SEC), Disclosure Insight, and your upcoming earnings season. ### Impact of a Shutdown on the SEC Some emergency exceptions apply, but they remain rare. Therefore, nearly everything we outline below applies. [Subscribe now](https://www.disclosureinsight.com/subscribe) **SEC EDGAR filings:** As with past shutdowns, the SEC’s EDGAR system remains fully operational. You’ll still see the filings you expect such as 10-Q’s 10-K’s, and 8-K’s. Don’t expect to new SEC comment letters posted, though. **Division of Enforcement:** This is where the investigations take place. Most, if not all, investigative activity pauses. No new subpoenas are expected. Expect few, if any, new SEC investigations to start. Tips from outsiders will likely not be reviewed. **Division of Corporation Finance:** This is where public company filings are reviewed, including new registrations. As noted above, companies can, and are required to continue to file their quarterly earnings reports and other regular disclosures on time. SEC staff review and comment on these reports will pause. That means expect few, if any, new SEC comment letters until funding is restored. Further, **the review of IPOs stop**, creating unwanted delays for those companies hoping to come public soon. We already heard that some IPO’s under review were facing longer timelines due to layoffs and departures of senior SEC staff since Trump returned to office. This doesn’t help. **SEC’s Office of the General Counsel:** Most General Counsel staff are furloughed, though matters previously scheduled involving the court system will likely proceed. **Freedom of Information Act requests:** All FOIA staff are furloughed for the duration of the shutdown. ### Disclosure Insight Impact **Unless the shutdown drags on, we expect minimal disruption to our publishing.** That’s largely because for the past month, the SEC has been sending us far more than we can typically process. As happens every year ahead of the federal government’s fiscal year end (September 30th), the SEC dumps a large volume of data on us. It’s a practice common across federal agencies, clearing the decks to improve year-end reporting. For our part, it usually takes us weeks to work through the September surge. This year, we’ll use the break to process what they sent. [Subscribe](#/portal/signup) ### SEC Investigation Updates: September 30, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-september-526/ Last updated: 2026-03-17T13:49:08.000Z **All-access clients are welcome to contact us anytime to learn more.** ***Click on the PDF here to access today’s report.*** [SEC Investigation Updates - September 30, 2025SEC Investigation Updates - September 30, 2025325 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/efcc8fe6-9883-47a8-a086-ec386579c3db.pdf "Download") [Subscribe](#/portal/signup) *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* *Our Terms of Service, relevant disclosures, and other legal notices can be* [*found here*](http://www.disclosureinsight.com/)*.* ### DI's Early Signals Report: September 25, 2025 URL: https://www.disclosureinsight.com/dis-early-signals-report-september-940/ Last updated: 2026-03-17T13:49:08.000Z ***Click on the PDF here to access a printable version of this report.*** [DI's Early Signals Report: September 25, 2025DI's Early Signals Report: September 25, 2025300 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/e1363235-3fa4-41e6-9bd6-d7c30475a1f3.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What’s an Early Signal? **DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity**. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation as “confirmed” after we file an administrative appeal and have received a response that says as much. **Important**: **The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security**. In its responses, the SEC did not disclose the details on investigative activity referenced herein. They may pertain to the conduct, transactions, and/or disclosures of the companies; but that is not yet confirmed. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. At this point, we believe the investigation does pertain to the conduct, transactions, and/or disclosures of the companies. 2. There is an investigation in the present day in which enforcement proceedings remain ongoing, however, they only relate to the company. An example is when a company gets caught up is a larger multi-company investigation that remains ongoing, but the company is no longer directly involved. 3. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 4. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 5. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. **All-access clients are welcome to contact us anytime to learn more.** [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### SEC Investigation Updates - September 19, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-september-f9e/ Last updated: 2026-03-17T13:49:09.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - September 19, 2025SEC Investigation Updates - NF - September 19, 2025347 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/1dcfa82e-3259-4aab-8330-40a3af6142da.pdf "Download") [Subscribe](#/portal/signup) ### SEC Investigation Updates: September 18, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-september-b2a/ Last updated: 2026-03-17T13:49:09.000Z **All-access clients are welcome to contact us anytime to learn more.** ## Today’s report - - **AGCO Corporation - AGCO** - **Alnylam Pharmaceuticals, Inc. - ALNY** - **Chevron Corporation - CVX** - **Crimson Wine Group Ltd - CWGL** - **Eli Lilly & Company - LLY** - **JAKKS Pacific, Inc. - JAKK** - **MACOM Technology Solutions - MTSI** - **TEVA Pharmaceutical Industries Ltd. - TEVA** - **TransUnion - TRU** - **Zscaler, Inc. - ZS** ***Click on the PDF here if you prefer a printable version of this report.*** [SEC Investigation Updates - September 18, 2025SEC Investigation Updates - September 18, 2025320 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/6f7c9c3e-2762-46a5-a3b7-813f920236b8.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### COMPANY COMMENTS ## AGCO Corporation – AGCO **Removed from Watch List.** Latest signal, dated 30-May-2025, suggested an SEC probe was ongoing. An appeal response dated 05-Sep-2025 now suggests SEC investigative activity involving this company is over. Cyber incident in May-2022 had sizable impact across the company’s operations. Cyber-related probes are getting cleared quickly now under Trump 2.0. ## Alnylam Pharmaceuticals, Inc. – ALNY **Removed from Watch List.** Latest signal, dated 16-Apr-2025, suggested an SEC probe was ongoing. However, as of 30-Jul-2025, our work concludes ongoing SEC enforcement proceedings do not appear to directly pertain to Alnylam's conduct, transactions, and/or disclosures. We learned Alnylam was involved in a sweeping SEC investigation into employment and separation agreements. Alnylam’s involvement ended in May-2025\. We also know the Audit Committee Chair left abruptly, per the 8-K filed 28-Sep-2023\. No reason given at the time. ## Chevron Corporation – CVX **New Warning.** **Added to DI Watch List.** Early signal of an undisclosed SEC investigation first received on 14-Apr-2025, later confirmed as an ongoing SEC investigation on 30-Jul-2025\. This is a change from 15-Jul-2024, when our work found no signs of SEC investigative activity. Lots of FCPA activity in Chevron’s history. **Disclosure**: *John P. Gavin, the owner of Disclosure Insight, owns shares of Chevron in a personal account.* ## Crimson Wine Group Ltd – CWGL **Early Signal Not Confirmed as an Ongoing Investigation** We received an early signal of an undisclosed SEC investigation at Crimson Wine Group on 16-Apr-2025\. However, as of 30-Jul-2025, our work concludes ongoing SEC enforcement proceedings do not appear to directly pertain to this company’s conduct, transactions, and/or disclosures. In Jul-2024, Crimson disclosed a cyber intrusion which likely triggered an SEC investigation now ended. Cyber-related probes are getting cleared quickly now under Trump 2.0. ## Eli Lilly & Company – LLY **Removed from Watch List.** Latest signal, dated 13-May-2025, suggested an SEC probe was ongoing. An appeal response, dated 02-Sep-2025, now suggests SEC investigative activity involving this company is over. In Jun-2024, LLY said the CFO was leaving for another opportunity, effective 09-Sep-2024\. The timing is notable given we got the early signal in Jul-2024. ## JAKKS Pacific, Inc. – JAKK **Early Signal Not Confirmed as an Ongoing Investigation** We received an early signal of an undisclosed SEC investigation at JAKKS on 12-May-2025\. However, as of 02-Sep-2025, our work concluded ongoing SEC enforcement proceedings do not appear to directly pertain to this company’s conduct, transactions, and/or disclosures. In Dec-2022, JAKKS disclosed a cyber intrusion which likely triggered an SEC investigation now ended. Cyber-related probes are getting cleared quickly now under Trump 2.0. ## MACOM Technology Solutions – MTSI **Early Signal Not Confirmed as an Ongoing Investigation** We received an early signal of an undisclosed SEC investigation at MACOM on 08-May-2025\. However, as of 02-Sep-2025, our work concluded ongoing SEC enforcement proceedings do not appear to directly pertain to this company’s conduct, transactions, and/or disclosures. We know nothing further about the ongoing proceedings. ## TEVA Pharmaceutical Industries Ltd. – TEVA **Warning Reiterated** **Maintained on DI Watch List.** Undisclosed SEC investigation now confirmed as ongoing two times since 06-Jun-2024, most recently on 30-Jul-2025\. Internal controls problem disclosed for the first time in the 10-K filed on 12-Feb-2024. ## TransUnion – TRU **New Warning.** **Added to DI Watch List.** Early signal of an undisclosed SEC investigation first received on 16-Apr-2025, later confirmed as an ongoing SEC investigation on 30-Jul-2025\. The investigation could easily be related to a restatement in Jan-2024; after which internal controls were still ineffective as of the Oct-2024 10-Q. They were effective again with the 10-K filed on 13-Feb-2025\. Cyber incident, Mar-2022. ## Zscaler, Inc. – ZS **Early Signal Not Confirmed as an Ongoing Investigation** We received an early signal of an undisclosed SEC investigation at Zscaler on 28-May-2025\. However, as of 02-Sep-2025, our work concluded ongoing SEC enforcement proceedings do not appear to directly pertain to this company’s conduct, transactions, and/or disclosures. We know nothing further about the ongoing proceedings. ***\-- John P. Gavin, CFA, NACD.DC*** [Subscribe](#/portal/signup) *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* *Our Terms of Service, relevant disclosures, and other legal notices can be* [*found here*](http://www.disclosureinsight.com/)*.* ### DI's Early Signals Report: September 17, 2025 URL: https://www.disclosureinsight.com/dis-early-signals-report-september-877/ Last updated: 2026-03-17T13:49:09.000Z ***Click on the PDF here to access a printable version of this report.*** [DI's Early Signals Report: September 17, 2025DI's Early Signals Report: September 17, 2025305 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/234a67d1-7c4f-4b59-a50d-dda7f87c2887.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What’s an Early Signal? **DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity**. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation as “confirmed” after we file an administrative appeal and have received a response that says as much. **Important**: **The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security**. In its responses, the SEC did not disclose the details on investigative activity referenced herein. They may pertain to the conduct, transactions, and/or disclosures of the companies; but that is not yet confirmed. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. At this point, we believe the investigation does pertain to the conduct, transactions, and/or disclosures of the companies. 2. There is an investigation in the present day in which enforcement proceedings remain ongoing, however, they only relate to the company. An example is when a company gets caught up is a larger multi-company investigation that remains ongoing, but the company is no longer directly involved. 3. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 4. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 5. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. **All-access clients are welcome to contact us anytime to learn more.** [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### DI's Early Signals Report: September 10, 2025 URL: https://www.disclosureinsight.com/dis-early-signals-report-september/ Last updated: 2026-03-17T13:49:09.000Z ***Click on the PDF here to access a printable version of this report.*** [DI's Early Signals Report: September 10, 2025DI's Early Signals Report: September 10, 2025301 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/b836c67f-e5b3-4836-8bad-33f57c0d8b4a.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What’s an Early Signal? **DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity**. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation as “confirmed” after we file an administrative appeal and have received a response that says as much. **Important**: **The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security**. In its responses, the SEC did not disclose the details on investigative activity referenced herein. They may pertain to the conduct, transactions, and/or disclosures of the companies; but that is not yet confirmed. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. At this point, we believe the investigation does pertain to the conduct, transactions, and/or disclosures of the companies. 2. There is an investigation in the present day in which enforcement proceedings remain ongoing, however, they only relate to the company. An example is when a company gets caught up is a larger multi-company investigation that remains ongoing, but the company is no longer directly involved. 3. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 4. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 5. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. All-access clients are welcome to contact us anytime to learn more. **All-access clients are welcome to contact us anytime to learn more.** [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### DI's Early Signals Report: August 28, 2025 URL: https://www.disclosureinsight.com/dis-early-signals-report-august-28/ Last updated: 2026-03-17T13:49:09.000Z ***Click on the PDF here to access a printable version of this report.*** [DI's Early Signals Report: August 28, 2025DI's Early Signals Report: August 28, 2025298 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/ea0be678-775f-4630-9c8a-cbf35eef1b3a.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What’s an Early Signal? **DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity**. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation as “confirmed” after we file an administrative appeal and have received a response that says as much. **Important**: **The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security**. In its responses, the SEC did not disclose the details on investigative activity referenced herein. They may pertain to the conduct, transactions, and/or disclosures of the companies; but that is not yet confirmed. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. At this point, we believe the investigation does pertain to the conduct, transactions, and/or disclosures of the companies. 2. There is an investigation in the present day in which enforcement proceedings remain ongoing, however, they only relate to the company. An example is when a company gets caught up is a larger multi-company investigation that remains ongoing, but the company is no longer directly involved. 3. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 4. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 5. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. All-access clients are welcome to contact us anytime to learn more. **All-access clients are welcome to contact us anytime to learn more.** [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### SEC Investigation Updates - August 20, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-august-525/ Last updated: 2026-03-17T13:49:09.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - August 20, 2025SEC Investigation Updates - NF - August 20, 2025351 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/58631b69-cacc-4610-bf3f-69751fdf182e.pdf "Download") [Subscribe](#/portal/signup) ### DI's Early Signals Report: August 20, 2025 URL: https://www.disclosureinsight.com/dis-early-signals-report-august-20/ Last updated: 2026-03-17T13:49:10.000Z ***Click on the PDF here to access a printable version of this report.*** [DI's Early Signals Report: August 20, 2025DI's Early Signals Report: August 20, 2025327 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/0e304c02-916c-46cd-a411-99d6ad9fa879.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What’s an Early Signal? **DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity**. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation as “confirmed” after we file an administrative appeal and have received a response that says as much. **Important**: **The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security**. In its responses, the SEC did not disclose the details on investigative activity referenced herein. They may pertain to the conduct, transactions, and/or disclosures of the companies; but that is not yet confirmed. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. At this point, we believe the investigation does pertain to the conduct, transactions, and/or disclosures of the companies. 2. There is an investigation in the present day in which enforcement proceedings remain ongoing, however, they only relate to the company. An example is when a company gets caught up is a larger multi-company investigation that remains ongoing, but the company is no longer directly involved. 3. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 4. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 5. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. All-access clients are welcome to contact us anytime to learn more. **All-access clients are welcome to contact us anytime to learn more.** [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### DI Audio: Dell Technologies - Maybe Not the Best Pony to Bet on in the Hot AI Sector URL: https://www.disclosureinsight.com/di-audio-dell-technologies-inc-dell/ Last updated: 2025-08-18T23:58:57.000Z DI Audio: Dell Technologies - Maybe Not the Best Pony to Bet on in the Hot AI Sector 0:00 /200 1× ### Dell Technologies, Inc. – DELL $138.13 US Mkt Cap: $93.5 B [\[Re-post\] DI Report: Dell Technologies - DELL 2025-0618\[Re-post\] DI Report: Dell Technologies - DELL 2025-0618356 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/1b1123e7-4065-4a35-962b-2f75766e7da2.pdf "Download") ### Alert: Abrupt departure of Chief Accounting Officer ### **From the Dell Technologies, Inc. 8-K filed on 12-Aug-2025:** > **Item 5.02 *Departure of Directors or Certain Officers*; Election of Directors; Appointment of Certain Officers; Compensatory Arrangements of Certain Officers.** > > (b) On August 7, 2025, Brunilda (Bruny) Rios, Senior Vice President, Corporate Finance and Chief Accounting Officer of Dell Technologies Inc. (the “Company”), notified the Company of her decision to step down from her position as the Company’s principal accounting officer for personal reasons, effective as of August 8, 2025\. Ms. Rios will continue to serve as a Senior Vice President of the Company. > > (c) In connection with Ms. Rios’s departure from the role of principal accounting officer, Richard Troy Sharp, formerly Vice President, Corporate Accounting and Reporting of the Company, has been appointed as Senior Vice President, Corporate Finance and Chief Accounting Officer of the Company, in which position he will serve as the Company’s principal accounting officer, effective August 8, 2025. > > Mr. Sharp, age 41, has served in various positions with the Company since July 2012\. Mr. Sharp has served as Vice President, Corporate Accounting and Reporting since April 2021, and prior to that service, as Director, M&A and Treasury Accounting since March 2017. > > Mr. Sharp will continue to be eligible to participate in severance, retirement, welfare and benefit plans and programs generally available to other employees of the Company, including the Dell Technologies Inc. 2023 Stock Incentive Plan, which is described in the Company’s proxy statement on Schedule 14A, filed with the *Securities and Exchange* Commission on May 16, 2025. > > In connection with this appointment, the Company has approved compensation to Mr. Sharp consisting of an annual base salary of $368,100 and a target annual bonus in an amount equal to 55% of such base salary, pro-rated for the fiscal year ending January 30, 2026, calculated from August 8, 2025\. Additional information referred to in Item 5.02(c)(3) of Form 8-K has not been determined as of the date of this report. > > **SIGNATURES** > > Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized. > > Date: August 12, 2025 > > **Dell Technologies Inc.** > > By:/s/ Christopher A. GarciaChristopher A. Garcia > Senior Vice President and Assistant Secretary (Duly Authorized Officer) [Subscribe now](https://www.disclosureinsight.com/subscribe) *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* *Neither John Gavin nor Disclosure Insight holds any positions or ownership interests in the companies cited in today’s report.* *Our Terms of Service, relevant disclosures, and other legal notices can be* [*found here*](http://www.disclosureinsight.com/)*.* ### DI Audio: Danger in Carvana’s Newly-Disclosed SEC Subpoena URL: https://www.disclosureinsight.com/di-audio-danger-in-carvanas-newly/ Last updated: 2026-03-17T13:49:10.000Z DI Audio: Danger in Carvana’s Newly-Disclosed SEC Subpoena 0:00 /200 1× ### Carvana Co. – CVNA $345.25 US Mkt Cap: $74.7 B [DI Report: Carvana - CVNA 2025-0812DI Report: Carvana - CVNA 2025-0812466 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/3683e8b5-f0be-4e64-9942-768083e45903.pdf "Download") ### Summary & Opinion: *New Warning. Run fast, run far.* Since it reported in late July, the Street has happily cheered Carvana’s great earnings, while overlooking a recently disclosed SEC subpoena. Not us. We see a dangerous connection between Carvana’s disclosure of an SEC subpoena in the 10-Q filed 30-Jul-2025; a Hindenburg Research warning in Jan-2025; and, the disclosure of an SEC inquiry buried in an 8-K, over five years ago, in Mar-2020\. Yes, five years ago. Relevant excerpts from the Mar-2020 8-K, the Jan-2025 Hindenburg Research report, and Carvana’s SEC subpoena disclosure appear later in this report. In its 10-Q filed 30-Jul-2025, Carvana largely attributes its SEC subpoena to a report by, “a now-defunct short-selling firm,” that published a warning on the company in Jan-2025\. Anyone following Carvana knows it was Hindenburg Research that published a warning on Carvana in Jan-2025\. This is consistent with our work which found the SEC often opened investigations into companies that appeared in Hindenburg’s reports in the past, usually within 30 days of publication. The Hindenburg report was published on 02-Jan-2025\. Carvana said it “voluntarily contacted” the SEC about it, presumably, shortly thereafter. A related SEC subpoena wasn’t disclosed until 30-Jul-2025, many months later. **In our experience these disclosure delays often mean something changed, and usually not for the better.** ### Carvana has a long history of keeping ongoing SEC investigative activity from investors. Even absent any connection to a disclosure made in Mar-2020, just the fact Carvana is telling you about *any* SEC subpoena now is itself meaningful. First, that Mar-2020 disclosure was never repeated or updated at any time over the past five years. Next, we repeatedly found active SEC investigative activity at Carvana, last confirmed as ongoing in Apr-2025\. Yet we found no clear disclosures of SEC investigative activity at Carvana since Mar-2020. ### Carvana’s Added Risk With the Trump SEC Even if Carvana’s newly-disclosed SEC subpoena is solely the result of Hindenburg’s Jan-2025 warning, as the company wants us to believe, that alone is quite bad for the company. Why? Trump’s back in the White House. Under the Trump 2.0 SEC, the threshold for an SEC investigation to become formal is now much higher than it was in the past. Keep in mind, subpoenas are only issued in formal SEC investigations. If Carvana’s newly-disclosed SEC subpoena is solely the result of Hindenburg’s Jan-2025 warning, that tells us the company’s SEC investigation met that heightened standard. That has terrible implications for investors. Before we move on, keep in mind that anything that came up as a result of that 2020 SEC investigation could easily factor into any investigation of Carvana today. [Subscribe now](https://www.disclosureinsight.com/subscribe) ### DI’s Findings Early Signal of a possible SEC investigation first found at Carvana in Oct-2020\. Since then, an active and ongoing SEC investigation has been confirmed repeatedly, most recently in Apr-2025. ### DI’s Take Again, we think that newly-disclosed subpoena is merely the latest in a long-running SEC investigation of Carvana. The easiest way to find out is to just ask the company these few questions: - You never gave us an update on that SEC inquiry you disclosed back in Mar-2020\. Whatever came of that? - When was your first contact with the SEC on the investigation you disclosed in your Jul-2025 10-Q? - Have there been other subpoenas? If so, how many and when? ### Carvana’s March 2020 “Stealth” Disclosure of an Informal SEC investigation Early in the covid pandemic, on 30-Mar-2020, Carvana filed an 8-K, ostensibly to give investors a “Current Update on the Business.” Tucked within this same 8-K, Carvana said this – > In addition, we have received **a voluntary request from the SEC** requesting information **about our related party disclosure** and **accounting policies and procedures for historical loan sales and refinancings**. We are providing relevant documentation in response to this request. - Nowhere in the above disclosure excerpt are words one would expect, such as inquiry, investigation, probe, informal, formal, or subpoena. - This disclosure sounds routine, harmless even. It’s not. This represents the stealth disclosure of an SEC investigation, in this case, an informal SEC inquiry. ### Carvana’s July 2025 Disclosure of an SEC Subpoena - From the Carvana Co 10-Q filed on 30-Jul-2025 > In January 2025, a now-defunct short-selling firm published a report including inaccurate, incomplete, and otherwise misleading information about us. We engaged outside legal counsel to independently evaluate the allegations, and voluntarily contacted the U.S. Securities and Exchange Commission (“SEC”). Based upon that evaluation and our own review, we reaffirmed our conclusion that the allegations raised in the short-seller’s report were inaccurate, incomplete, and misleading. In June 2025, **we received a subpoena from the SEC requesting information that we believe primarily relates to the allegations raised by the report.** We are fully cooperating with the SEC Staff. ## Notable Events **Mar-2020:** Carvana makes what we called at the time a “stealth disclosure” of an SEC inquiry buried within an 8-K at the time. We detail it below, next page. **Sep-2021:** Disclosure Insight, then known as Probes Reporter, issued a warning on Carvana in Sep-2021, at $330/share. This went on to become one of our best calls, as the stock fell to about $5 by Dec-2022\. Our full Sep-2021 warning is worth your time. It’s posted with this report. ### Comparing Carvana’s March 2020 8-K to Hindenburg’s January 2025 Allegations ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/64bd1ca2-8cef-4545-8118-d89334d9dc95_711x969.png) [Subscribe now](https://www.disclosureinsight.com/subscribe) ### Addendum: Disclosure Insight/Probes Reporter September 21, 2021 Warning on Carvana - [Download](https://www.disclosureinsight.com/api/v1/file/1970448a-1bb9-468a-83e2-d575ee854093.pdf) ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/8cbb7730-e801-402a-9252-9673c4d82b7b_903x533.png) [DI Report Carvana September 20, 2021DI Report Carvana September 20, 2021380 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/ac03207b-9918-4267-a628-527cc00427ff.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* *Neither John Gavin nor Disclosure Insight holds any positions or ownership interests in the companies cited in today’s report.* *Our Terms of Service, relevant disclosures, and other legal notices can be* [*found here*](http://www.disclosureinsight.com/)*.* ### DI Audio: Recognition of Revenue? URL: https://www.disclosureinsight.com/di-audio-recognition-of-revenue/ Last updated: 2025-08-02T14:20:32.000Z DI Audio: Recognition of Revenue? 0:00 /200 1× In today’s DI Audio session, I walk you through an example of a company that uses clever word choice to mask an underlying problem that could easily lead to restatement. Using a warning we recently published on CrowdStrike (CRWD), I also show you some things to look for anytime a company you care about discloses an SEC investigation for the first time. Even if you don't care about this particular company, I think you will get a lot out of this DI Audio session when it comes to your own investment decision-making. I hope you enjoy the audio and I welcome your feedback. *\- John* PS. You can see the original warning on CrowdStrike here - [*CrowdStrike: Restatement Risk Now Elevated*](https://www.disclosureinsight.com/p/crowdstrike-restatement-risk-now), June 12, 2025 ***\-- John P. Gavin, CFA, NACD.DC*** [Subscribe now](https://www.disclosureinsight.com/subscribe) *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* *Neither John Gavin nor Disclosure Insight holds any positions or ownership interests in the companies cited in today’s report.* *Our Terms of Service, relevant disclosures, and other legal notices can be* [*found here*](http://www.disclosureinsight.com/)*.* ### SEC Investigation Updates: July 30, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-july-30/ Last updated: 2026-03-17T13:49:10.000Z **All-access clients are welcome to contact us anytime to learn more.** ## Today’s report - - **Park National Corp. - PRK** - **U-Haul Holding Co. - UHAL** - **Unisys Corporation - UIS** ***Click on the PDF here if you prefer a printable version of this report.*** [SEC Investigation Updates - July 30, 2025SEC Investigation Updates - July 30, 2025288 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/20a7008f-3a99-4f87-94b9-7848de1e786d.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### COMPANY COMMENTS ### Park National Corp. – PRK **New Warning.** Early signal of an undisclosed SEC investigation first received on 02-Apr-2025, later confirmed as an ongoing SEC investigation on 18-Jul-2025\. **Added to DI Watch List.** ### U-Haul Holding Co. – UHAL **New Warning.** Early signal of an undisclosed SEC investigation first received on 27-Mar-2025, later confirmed as an ongoing SEC investigation on 18-Jul-2025\. Not sure what to make of this. Auditor change in Sep-2023, and internal controls problems 2023-2024\. Yet as of Apr-2024, our work found no signs of SEC investigative activity. **Added to DI Watch List.** ### Unisys Corporation – UIS **New Warning.** Early signal of an undisclosed SEC investigation first received on 03-Apr-2025, later confirmed as an ongoing SEC investigation on 18-Jul-2025\. Unisys disclosed a cyber investigation that ended in Oct-2024\. Previously, Unisys dumped its auditor 17-Mar-2023\. Delayed filings, an internal investigation, and internal controls issues were repeatedly disclosed in Nov-2022\. Those legacy issues may still be causing SEC problems today. **Added back to DI Watch List.** ***\-- John P. Gavin, CFA, NACD.DC*** [Subscribe](#/portal/signup) *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* *Our Terms of Service, relevant disclosures, and other legal notices can be* [*found here*](http://www.disclosureinsight.com/)*.* ### Introducing DI Audio URL: https://www.disclosureinsight.com/introducing-di-audio/ Last updated: 2025-07-26T13:55:18.000Z Introducing DI Audio 0:00 /200 1× This one-minute audio clip will explain something new I’m doing to add value to our research. ### Note: If you are using an iPhone the audio file may not load. Your iPhone may use AirPlay to try to play the sound. This is not a stream. AirPlay won’t work. ### Here’s the solution - - Press and hold the PLAY link in the email. - A menu will pop up. - Choose a browser and the audio should easily load and play. We’ve let Substack support know of this problem. ### SEC Investigation Updates: July 24, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-july-24/ Last updated: 2026-03-17T13:49:11.000Z **All-access clients are welcome to contact us anytime to learn more.** ## Today’s report - - **AT&T, Inc. - T** - **Hologic, Inc. - HOLX** - **Medallion Financial Corp. - MFIN** - **Microsoft Corp. - MSFT** - **Sapiens International Corp. N.V. - SPNS** - **Uber Technologies, Inc. - UBER** ***Click on the PDF here if you prefer a printable version of this report.*** [SEC Investigation Updates - July 24, 2025SEC Investigation Updates - July 24, 2025304 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/83598de8-3a32-47b0-bce9-ab65f783a8f3.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### COMPANY COMMENTS ### AT&T, Inc. – T **New Warning.** Early signal of an undisclosed SEC investigation first received on 24-Jan-2025, then confirmed as an ongoing investigation on 18-Jul-2025\. Multiple SEC investigations found, at least four of them. Two appear to have ended; we received a copy of a termination letter related to a third one that involved a cyber incident. An unspecified number of investigations remain active and ongoing, as of 18-Jul-2025\. We found multiple undisclosed SEC probes of AT&T in recent years, including one that generated over 2,500 boxes of records. This was among the largest we ever tracked, yet the company rationalized keeping it from investors. **Added back to DI Watch List.** ## Hologic Inc. – HOLX **Warning Reiterated** Undisclosed SEC investigation now confirmed as ongoing two times since 09-Aug-2024, most recently on 18-Jul-2025\. **Maintained on DI Watch List.** ## Medallion Financial Corp. – MFIN **Disclosed SEC Investigation Finally Settled – 8 Years Later** In its Aug-2021 10-Q, Medallion Financial finally disclosed an SEC investigation we repeatedly warned about since we got our early signal of it in Aug-2017. Now, in the 8-K filed on 02-Jun-2025, MFIN says it finally resolved its related SEC litigation. Our latest information, dated 18-Jul-2025, tells us there are no other ongoing SEC exposures. ## Microsoft Corp. – MSFT **Warning Reiterated** Undisclosed SEC investigations now confirmed as ongoing two times since 26-Mar-2024\. An unspecified number of investigations remain active and ongoing, as of 18-Jul-2025\. A separate investigation appears to have ended. It’s possible it’s related to a cyber incident, first disclosed in Jan-2024\. Cyber-related probes are getting cleared quickly now under Trump 2.0\. **Maintained on DI Watch List.** ## Sapiens International Corp. NV – SPNS **Warning Reiterated** Undisclosed SEC investigation now confirmed as ongoing three times since 02-May-2023, most recently on 18-Jul-2025\. **Maintained on DI Watch List.** ## Uber Technologies, Inc. – UBER **New Warning.** Early signal of an undisclosed SEC investigation first received on 17-Jan-2025, later confirmed as an ongoing SEC investigation on 02-May-2025\. **Added to DI Watch List.** ***\-- John P. Gavin, CFA, NACD.DC*** [Subscribe](#/portal/signup) *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* *Our Terms of Service, relevant disclosures, and other legal notices can be* [*found here*](http://www.disclosureinsight.com/)*.* ### DI's Early Signals Report: July 23, 2025 URL: https://www.disclosureinsight.com/dis-early-signals-report-july-23/ Last updated: 2026-03-17T13:49:11.000Z ***Click on the PDF here to access a printable version of this report.*** [DI's Early Signals Report: July 23, 2025DI's Early Signals Report: July 23, 2025318 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/3dc70000-ee88-41c3-a66b-4d0356ff92dd.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What’s an Early Signal? **DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity**. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation as “confirmed” after we file an administrative appeal and have received a response that says as much. **Important**: **The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security**. In its responses, the SEC did not disclose the details on investigative activity referenced herein. They may pertain to the conduct, transactions, and/or disclosures of the companies; but that is not yet confirmed. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. At this point, we believe the investigation does pertain to the conduct, transactions, and/or disclosures of the companies. 2. There is an investigation in the present day in which enforcement proceedings remain ongoing, however, they only relate to the company. An example is when a company gets caught up is a larger multi-company investigation that remains ongoing, but the company is no longer directly involved. 3. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 4. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 5. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. All-access clients are welcome to contact us anytime to learn more. **All-access clients are welcome to contact us anytime to learn more.** [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### SEC Investigation Updates - July 22, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-july-22/ Last updated: 2026-03-17T13:49:11.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - July 22, 2025SEC Investigation Updates - NF - July 22, 2025348 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/98b16975-6587-4044-976b-e4965e60f43c.pdf "Download") [Subscribe](#/portal/signup) ### SEC Investigation Updates: July 15, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-july-15/ Last updated: 2026-03-17T13:49:11.000Z **All-access clients are welcome to contact us anytime to learn more.** ## Today’s report - - **e.l.f. Beauty, Inc. - ELF** - **Everest Group, Ltd. - EG** - **Fulgent Genetics, Inc. - FLGT** ***Click on the PDF here if you prefer a printable version of this report.*** [SEC Investigation Updates - July 15, 2025SEC Investigation Updates - July 15, 2025336 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/cfa0c3d8-194f-4805-8b56-bafce83266fa.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### COMPANY COMMENTS ### **e.l.f. Beauty, Inc. – ELF** **New Warning.** Early signal received on 24-Jan-2025, then confirmed as an ongoing investigation on 24-Apr-2025\. First investigation we found since we started covering ELF in Apr-2020\. **Added to DI Watch List.** ### **Everest Group, Ltd. – EG** **New Warning. Abrupt departure of CEO, Jan-2025.** Early signal received on 29-Jan-2025, then confirmed as an ongoing SEC investigation on 24-Apr-2025\. First SEC investigation we found since we started covering Everest Group in Nov-2012. **From the Everest Group 8-K filed on 08-Jan-2025:** > On January 3, 2025, Juan C. Andrade, President and Chief Executive Officer and director of Everest Group, Ltd. (“Everest”) notified Everest that he was resigning to pursue another opportunity. **Added to DI Watch List.** ### **Fulgent Genetics, Inc. – FLGT** **Update on Disclosed SEC Investigation - SEC investigation ends, but DOJ overhang remains.** Fulgent’s 10-Q filed 02-May-2025, confirms the SEC has closed its probe into 2018–2020 disclosures and lab billing. Our research, dated 22-May-2025, tells us there remain no ongoing exposures. A preliminary enforcement recommendation from May 2024 was dropped in April 2025, and Fulgent reversed a $1M contingency. Management mentioned the SEC resolution on its earnings call but did not address ongoing DOJ investigations. As the 10-Q excerpt shows (next page), the DOJ investigation is still active (the SEC investigation is noted in the final paragraph). While the SEC closure is positive, investors should remain cautious until the DOJ matter is resolved. **As disclosed in the 10-Q, the DOJ’s focus areas include the following –** - Medically unnecessary testing - Improper billing practices - Violations of Anti-Kickback and Stark Law - Potential false claims to the COVID Uninsured Program. - Related Civil CIDs target records involving named customers. In addition, the Health Resources and Services Administration (HRSA) is conducting an audit reviewing \~$549M in COVID test reimbursements from 2020–2022. **From the Fulgent Genetics, Inc. 10-Q filed on 02-May-2025:** > As previously disclosed in the Company’s periodic reports filed pursuant to the Securities Exchange Act of 1934, as amended, or the Exchange Act, the Company has received a Civil Investigative Demand, or CID, issued by the U.S. Department of Justice, or the DOJ, pursuant to the False Claims Act related to its investigation of allegations of medically unnecessary laboratory testing, improper billing for laboratory testing, and remuneration received or provided in violation of the Anti-Kickback Statute and the Stark Law. Among other things, this CID requests information and records relating to certain of the Company’s customers named in this CID. > > Similar to other laboratories in the industry, the Company has been subject to an audit by the U.S. Health Resources and Services Administration, or HRSA, with respect to its reimbursement for COVID-19 tests furnished to patients believed to be uninsured. The Company recorded approximately $548.9 million of reimbursements from HRSA under the Uninsured Program during the years ended December 31, 2022, 2021, and 2020\. There is uncertainty with respect to the methodology HRSA will use in its audit and whether and how HRSA will extrapolate audit results. The Company has provided HRSA’s auditors with requested information in connection with its audit in an effort to resolve any issues related to its audit, including any reimbursed amounts that may need to be returned to HRSA. The Company has also received a CID issued by the DOJ pursuant to the False Claims Act related to the DOJ’s investigation as to whether the Company submitted or caused to be submitted false claims to the Uninsured Program. > > The Company is fully cooperating with the DOJ in connection with the CIDs that it has received. The Company cannot currently predict when these CIDs and HRSA audit matters will be resolved, the reasonable or likely outcome of these matters, or their potential impact, which may materially and adversely affect the Company’s business, prospects, and financial condition. These matters are not formal claims, and discussions and investigations remain ongoing. As such, the Company cannot reasonably estimate the loss or range of loss, if any, that may result from any material government investigations, audits, and reviews in which it is currently involved, given the inherent difficulty in predicting regulatory action, fines and penalties, if any, and the various remedies and levels of judicial review available to the Company in the event of an adverse finding. As a result, the Company has not recorded any liability related to these CIDs or audit matters. > > In addition, and as previously disclosed, the SEC was conducting a non-public formal investigation, which related to (i) the matters raised in the requests for the CID regarding allegations of medically unnecessary laboratory testing, improper billing for laboratory testing, and remuneration received or provided in violation of the Anti-Kickback Statute and the Stark Law and (ii) the Company’s Exchange Act reports filed for 2018 through 2020. > > ***On May 6, 2024, the SEC staff advised the Company that the SEC staff made a preliminary determination to recommend that the SEC file an enforcement action against the Company based on a corporate negligence theory, which, if authorized, would have alleged violations of the Securities and Exchange Act. In April 2025, the SEC advised the Company that it had concluded this investigation, with no enforcement action recommended. The Company previously recorded a $1.0 million potential liability with respect to this matter and is no longer recording any potential liability in connection with this matter.*** > > ***\[Emphasis added\]*** ***\-- John P. Gavin, CFA, NACD.DC*** [Subscribe](#/portal/signup) *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* *Our Terms of Service, relevant disclosures, and other legal notices can be* [*found here*](http://www.disclosureinsight.com/)*.* ### SEC Investigation Updates - July 14, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-july-14/ Last updated: 2026-03-17T13:49:12.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - July 14, 2025SEC Investigation Updates - NF - July 14, 2025335 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/2a0334ce-71fe-4a2e-8243-17851ffcdd2e.pdf "Download") [Subscribe](#/portal/signup) ### DI's Early Signals Report: July 11, 2025 URL: https://www.disclosureinsight.com/dis-early-signals-report-july-11/ Last updated: 2026-03-17T13:49:12.000Z ***Click on the PDF here to access a printable version of this report.*** [DI's Early Signals Report: July 11, 2025DI's Early Signals Report: July 11, 2025299 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/621545e8-48ce-42cd-aaa0-5e35f5310cec.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What’s an Early Signal? DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation as “confirmed” after we file an administrative appeal and have received a response that says as much. **Important:** The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security. In its responses, the SEC did not disclose the details on investigative activity referenced herein. All we know is that they somehow pertain to the conduct, transactions, and/or disclosures of the companies. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. 2. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 3. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 4. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. **All-access clients are welcome to contact us anytime to learn more.** [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### The Disclosure Insight Watch List Warnings Are Improving URL: https://www.disclosureinsight.com/the-disclosure-insight-watch-list/ Last updated: 2026-03-17T13:49:12.000Z ## From John’s Desk … **“A moment’s insight is sometimes worth a life’s experience.”** – *Oliver Wendell Holmes Sr.* ### After 25 Years Following the SEC … Those familiar with my work know that I’ve spent the past 25 years following public company interactions with the US Securities and Exchange Commission, the SEC. - In the late 90s, I pioneered using the Freedom of Information Act as an investment research tool. - Those analytically-rich SEC comment letters many of you now use in your own research have been freely available online since 2004 – largely because of my early FOIA work. - In my opinion, no one on Wall Street can interpret a disclosed SEC investigation as well as I can. - No one outside of government has the expertise and database my Disclosure Insight research operation has built over these many years. **I’m not telling you this to brag.** I’m telling you because it sets the stage for some significant changes we’re making to the DI Watch List—starting with the July update, due out soon. Let me explain. **We wanted to see if we could improve the quality of the warnings appearing on the DI Watch List** – those companies with confirmed, undisclosed SEC investigations. I’ve always been happy with the quality of this research product, but could we make it even better—if so, how? ### A 10-Year Look-Back Inside DI’s Database. This past month we conducted an in-depth analysis of the FOIA responses that form the backbone of the Watch List. Aided by my 25 years of experience focused on the SEC, we studied language and FOIA response patterns going back to 2014—more than a decade of history. We then factored in enforcement trends and shifting SEC priorities observed since the Trump administration returned to office. The outcome of this exercise was not only revealing – it changed what companies appear – and stay – on the Watch List. In short, this study has led to a meaningful analytical upgrade to this widely followed report. ### What Are We Changing? In the past, any company with undisclosed SEC investigative activity that was recently confirmed as active and ongoing was eligible for inclusion on the Watch List. Going forward, that’s not enough. **The standard for Watch List inclusion is now tighter.** **Starting with the July Watch List update**, a company will only appear on the DI Watch List if we believe the ongoing and undisclosed SEC investigative activity we find directly pertains to its conduct, transactions, and/or disclosures. That is, for a company to be on the Watch List, we have to be convinced that the investigative activity is centered on the company itself. That’s long been our goal, only now we think we can better execute on it. [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What Companies Are No Longer Eligible For Inclusion On the DI Watch List? Our review surfaced several scenarios where enforcement proceedings remain active and ongoing, yet available indicators suggest the company is no longer the central focus. Some were clear; others emerged only when we stepped back and studied language and response patterns across those 10 years of our data included in this analysis. ### Examples of Companies No Longer Included on the Watch List: - A company where SEC enforcement proceedings might involve former executives, outside firms, or other third parties related to the company. - Companies that appear to only have post-investigation compliance and/or reporting obligations. - A company included in a broader inquiry that remains ongoing, but the company itself is no longer directly involved. Examples: Cyber intrusions; whistleblower protection rules; and, off-channel communications by financial professionals. ### What Does This Mean For You Right Now? After close review, we expect about 30 companies of the 119 appearing in our June Watch List update no longer meet our higher standard. They’re coming off the list. ### What About DI’s Early Signals® Alerts? Our Early Signals alerts will still come out well before appearing on the SEC’s website, usually weeks later. But they are under review too. The data behind them remain unchanged. As before, we still expect about 80% of the companies appearing in one of our Early Signals reports will go on to have SEC investigative activity confirmed as active and ongoing. The percent of Early Signals companies that meet our tighter standard for Watch List inclusion remains to be seen. We doubt it will be 80%. We’ll keep you posted on this. Again, the July update to the DI Watch List comes out soon. You’ll see all the changes then. As always, I thank you for your ongoing support. Feel free to share this with others, as well as letting me know your thoughts on this new upgrade. - John ***John P. Gavin, CFA, NACD.DC*** [Subscribe](#/portal/signup) ### Dell’s Accounting Adjustments Raise Troubling Questions URL: https://www.disclosureinsight.com/dells-accounting-adjustments-raise/ Last updated: 2026-03-17T13:49:12.000Z ***Click here for a printable PDF version of this report. All-access clients are welcome to contact us anytime to discuss.*** [DI Report: Dell Technologies (DELL) 2025-0618DI Report: Dell Technologies (DELL) 2025-0618356 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/921cfaa3-d915-4e61-92be-2207b15540a6.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ## Dell Technologies, Inc. – DELL **$** **115.93 US Mkt Cap: $77.2 B** ### Summary and Opinion: Recent accounting issues at Dell deserve closer scrutiny. In February, Dell revised its financials after discovering $348 million in vendor credits recorded incorrectly. Not good. Let’s have a closer look. Back in 2010, the SEC charged the former Dell, Inc. and its senior executives with disclosure and accounting fraud. The SEC said Dell used undisclosed exclusivity payments from Intel, **a vendor**, to create "cookie-jar reserves" that concealed financial shortfalls. From 2002 to 2006, Intel’s payments were misrepresented as rebates, then diverted to boost Dell’s earnings when operating results fell short. Dell paid a $100 million penalty; Michael Dell, $4 million. ### Vendor Credits Are Again at Issue In its 8-K and earnings release of 27-Feb-2025, Dell Technologies said during the fourth quarter of fiscal 2025, it discovered accumulated credits from suppliers – **vendors** – that were not recorded, or not recorded in the correct period in its previously reported financial results. Dell said the error overstated cost of goods sold by approximately $200 million in fiscal 2024 and $148 million in fiscal 2025 for the nine months ended 01-Nov-2024\. The total credits at issue was $348 million. That $348 million is about $50 million, or six cents per share “accumulated” for each of the quarters identified. In 2010, the issue involved a single vendor, Intel. Today Dell says it initiated an investigation, which found that “certain procurement” employees, working with “certain suppliers,” were responsible for the credits, impacting the Client Solutions Group segment. Those Intel payments grew from about 10% of operating income in FY-2003 to 38% in FY-2006\. They peaked in the first quarter of FY-2007, at 76% of operating income, over $700 million. By comparison, the $348 million in vendor credits at issue today is smaller, sure. An extra six cents per share, accumulated each quarter? That is meaningful. ### An Undisclosed SEC Investigation Early signal of a possible SEC investigation at Dell was received on 07-Jan-2025\. On 02-May-2025, we learned of three SEC investigations in recent periods Two are closed, one was still ongoing, and undisclosed as of 02-May-2025. ### Ineffective Internal Controls - This is New Per the 10-Q filed 10-Dec-2024, disclosure controls were declared effective, as of 01-Nov-2024\. However, in its 8-K of 27-Feb-2025, Dell said its internal controls were declared ineffective due to issues tied to the adjustment, as of 31-Jan-2025\. Per that 8-K filed 27-Feb-2025 – > *The material weakness relates to the approval, communication, and recording of non-recurring credits owed from certain suppliers. The material weakness is the result of deficiencies in the design and implementation of controls over certain non-recurring credits owed from suppliers.* Per the 10-Q filed 10-Jun-2025, we see some internal controls progress, but they were still not effective, as of 02-May-2025. [Subscribe now](https://www.disclosureinsight.com/subscribe) ### **DI's Take** **Dell’s accounting problems have our spider senses tingling, and not in a good way.** The “Revision of Previously Issued Financial Statements” narrative feels a bit too tidy, with many gaps upon closer look. Meanwhile, the earnings calls are gushing with AI-euphoria. Who cares about some pesky, arcane, accounting adjustment when you’ve got a great AI story! ### Here's where we suggest the more thoughtful investor focus – - **Is the problem limited to Dell’s Client Solutions Group segment?** Given the wide array of vendors, complex supply chains, and reporting requirements, procurement is typically centralized at larger companies. At minimum, procurement policies, practices and protocols are. That suggests this problem may be more widespread than disclosed. The ongoing controls weakness bolsters this thinking. - **Procurement employees don’t make accounting entries – so where was the disconnect?** And who else knew – and approved – **t**hese questionable transactions? We look to the C-suite for answers – or failures here. - **The C-Suite and the Board:** Critically, what did the C-suite and board know – and when? Given the broader implications for the company, especially margin and EPS impact, one has to wonder if compensation was a factor. If so, to what extent? - **Use of round numbers:** As we said earlier, that $348 million is about six cents per share “accumulated” in each of the quarters identified. Or, just about $50 million per quarter. Forensic accountants often flag round numbers because they can suggest estimates rather than precise calculations, raising concerns about potential manipulation. - **Potential for cookie-jar accounting:** $348 million in accumulated credits may not seem meaningful against Dell’s $67.3 billion Cost of Net Revenue in FY-24 alone. But at 6 cents per share, per quarter? It’s certainly meaningful at that level. Even though the scale is much smaller than the 2010 fraud case, the nature of the vendor credits adjustment still indicates possible cookie-jar accounting, where reserves could be drawn down to smooth earnings. If that’s the case, reserves may now be depleted, thanks to he recent accounting revision —potentially increasing future earnings volatility. - **SEC follow-up:** Make sure to ask Dell what contact it’s had with the SEC’s Division of Enforcement in the last two years. They can tell you if they choose to. ## Final Word – Pay Attention to Dell’s Big Systems Upgrade. Tucked deep within the details of Dell’s efforts to address its internal controls problems, is a disclosure you don’t want to miss, though many likely already have. Specifically, Dell tells us the company is also in the midst of a meaningful upgrade to its systems. **From the Dell Technologies 10-Q filed on 10-Jun-2025 –** > *We are in the process of an ongoing business modernization initiative to advance our capabilities, leverage new technology, and optimize business processes to change the way we work and make decisions, improve business outcomes, and reduce costs. As part of this initiative, we are modernizing accounting and finance systems.* ***Source:*** Dell Technologies 10-Q filed on 10-Jun-2025 **Read that again.** Dell’s disclosure tells us that not only does the company have internal controls problems it has yet to fully tame, it is also in the midst of a massive systems upgrade partially aimed at resolving them. This calls for added diligence and caution with Dell’s story going forward. Using an SAP project as an example – a leading enterprise software system – seasoned investors have long joked that whenever a company announces a major SAP project, it typically takes twice as long and costs twice as much as management initially estimates. This reflects the well-known complexities and risks involved in large-scale systems upgrades. In closing, while the AI story is compelling and exciting, it should not distract from the fundamentals. Well-designed and functioning business processes and systems are what enable those new technologies to covert to revenue and earnings. Dell’s shortfalls have been significant enough to cause accounting issues and internal controls weaknesses. Management needs to provide clear communication on its ongoing business modernization initiative. This includes estimates on costs, timelines, and progress reports. Failing that, we recommend you ask them about it. ***– John P. Gavin, CFA, NACD.DC*** **Addendum: Relevant Dell Technologies Disclosures - Available in PDF, above** [Subscribe](#/portal/signup) *Disclosure Insight research provides data, commentary, and analysis on public company interactions with investors and with the SEC. Our work is heavily reliant on company disclosures and our expertise in using the Freedom of Information Act.* This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission. **Our Terms of Service, relevant disclosures, and other legal notices** [**can be found here**](http://www.disclosureinsight.com/)**.** ### SEC Investigation Updates: June 17, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-june-17/ Last updated: 2026-03-17T13:49:13.000Z **All-access clients are welcome to contact us anytime to learn more.** ## Today’s report - - **C3.ai, Inc. - AI** - **Caesars Entertainment Corp. - CZR** - **CNH Industrial NV - CNHI** - **FactSet Research Systems, Inc. - FDS** - **Nektar Therapeutics - NKTR** - **Science Applications International Corp. - SAIC** ***Click on the PDF here to access a printable version of this report.*** [SEC Investigation Updates - June 17, 2025SEC Investigation Updates - June 17, 2025301 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/8918a875-7ca3-40cd-a90f-3d86810f9b90.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### COMPANY COMMENTS ### **C3.ai, Inc. – AI** **Warning Reiterated. SEC investigation again confirmed as ongoing.** Early signal of a possible SEC investigation received on 08-Jul-2024\. Enforcement proceedings confirmed as ongoing two times since, most recently on 27-May-2025\. This remains our first time researching C3.ai. No clear disclosure of SEC investigative activity found in a search of SEC filings back to the 10-Q filed 01-Sep-2022. **Notable Item**: In early Apr-2023, shares of C3.ai lost nearly 40% after a short report published by Kerrisdale Capital. That easily could have been the catalyst that brought in SEC investigators. **Maintained on DI Watch List.** ### **Caesars Entertainment Corp. – CZR** **Warning Reiterated. SEC investigation again confirmed as ongoing.** Early signal of a possible SEC investigation received on 09-May-2024\. Enforcement proceedings confirmed as ongoing two times since, most recently on 27-May-2025\. This is a change from a response dated 29-Nov-2021, at which time no signs of ongoing SEC investigative activity were found. A search of SEC filings, back to the 10-Q filed 04-May-2022, found no clear disclosure of SEC investigative activity. **Notable Item**: In the 8-K filed 14-Sep-2023, a cyber intrusion was first disclosed. That could be what brought in SEC investigators. **Maintained on DI Watch List.** ### **CNH Industrial NV – CNHI** **Warning Reiterated. SEC investigation again confirmed as ongoing.** Early signal of a possible SEC investigation received on 15-May-2024\. Enforcement proceedings confirmed as ongoing two times since, most recently on 27-May-2025\. This remains our first time researching CNH Industrial. A search of SEC filings, back to the 6-K dated 05-May-2022, found no clear disclosure of SEC investigative activity. **Notable Item**: CEO resigned, per an 8-K filed 22-Apr-2024: On 20-Apr-2024, Scott Wine resigned as CEO effective as of 01-Jul-2024\. Timing of the CEO resignation is interesting since our work suggests CNH Industrial may have known about an SEC probe since at least May-2024\. **Maintained on DI Watch List.** ### **FactSet Research Systems, Inc. – FDS** **New Warning.** Early signal of a possible SEC investigation received on 26-Feb-2025\. Signal was then confirmed as an ongoing investigation on 13-May-2025 This is a change from a response dated 05-Jun-2024, at which time no signs of ongoing SEC investigative activity were found. A search of SEC filings, back to the 10-Q filed 03-Apr-2023, found no clear disclosure of SEC investigative activity. **Added to DI Watch List.** ### **Nektar Therapeutics – NKTR** **Warning Reiterated. SEC investigation again confirmed as ongoing.** An early signal of undisclosed SEC investigative activity first found on 07-Oct-2020\. Enforcement proceedings now confirmed as ongoing six times since, most recently on 27-May-2025\. No clear disclosure of SEC investigative activity found in a search of Nektar’s SEC filings back to Oct-2018\. **Notable Item**: Abrupt departure of CFO on 01-Jul-2022\. You never want to see the sudden departure of a CFO, even more so in the presence of an undisclosed SEC investigation. **Maintained on DI Watch List.** ### **Science Applications International Corp. – SAIC** **Warning Reiterated. SEC investigation again confirmed as ongoing.** Early signal of a possible SEC investigation received on 28-Jun-2024\. Enforcement proceedings confirmed as ongoing two times since, most recently on 27-May-2025\. This remains is a change from a response dated 23-Aug-2023, at which time no signs of ongoing SEC investigative activity were found. No clear disclosure of SEC investigative activity found in a search of SEC filings back to the 10-Q filed 06-Jun-2022\. This remains the first time finding an SEC investigation here since we started covering Science Applications in Sep-2015\. **Maintained on DI Watch List.** ***\-- John P. Gavin, CFA, NACD.DC*** [Subscribe](#/portal/signup) *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* *Our Terms of Service, relevant disclosures, and other legal notices can be* [*found here*](http://www.disclosureinsight.com/)*.* ### SEC Investigation Updates: June 13, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-june-13/ Last updated: 2026-03-17T13:49:13.000Z **All-access clients are welcome to contact us anytime to learn more.** ## Today’s report - - **A10 Networks, Inc. - ATEN** - **Chegg, Inc. - CHGG** - **Cognizant Technology Solutions Corp. - CTSH** - **Inter Parfums, Inc. - IPAR** ***Click on the PDF here to access a printable version of this report.*** [SEC Investigation Updates - June 13, 2025SEC Investigation Updates - June 13, 2025299 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/b0fc8994-3d55-48ea-aefd-8dd69b1e0de7.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### COMPANY COMMENTS ### A10 Networks, Inc. – ATEN **Warning Reiterated. SEC investigation again confirmed as ongoing.** Early signal of a possible SEC investigation received on 19-Mar-2024\. Enforcement proceedings confirmed as ongoing three times since, most recently on 24-Apr-2025\. We have meta data and over 700 pages of analytically-rich records from earlier SEC investigative activity, including a matter that ended in Sep-2019\. Disclosure Games® repeatedly found when A10 disclosed that SEC investigation. **Notable Item**: In the 10-K filed on 07-Feb-2023, a cyber intrusion was first disclosed. This from the company who’s tagline is, “Always Secure. Always Available.” It could also be what the SEC’s investigating. **Maintained on DI Watch List.** ### Chegg, Inc. – CHGG Warning Reiterated. SEC investigation again confirmed as ongoing. Early signal of undisclosed SEC investigative activity first found on 08-Nov-2023\. Enforcement proceedings confirmed as ongoing two times since, most recently on 13-May-2025\. No clear disclosure of SEC investigative activity found in a search of SEC filings back to the 10-Q filed 01-Nov-2021\. This remains the first sign of an SEC investigation we found since we started covering Chegg in Dec-2016\. Maintained on DI Watch List. ### Cognizant Technology Solutions Corp. – CTSH **Warning Reiterated. SEC investigation again confirmed as ongoing.** Early signal of undisclosed SEC investigative activity first found on 11-May-2017\. Enforcement proceedings now confirmed as ongoing eleven times since that first early signal way back in 2017, most recently on 13-May-2025\. There has been no new SEC activity disclosed since an earlier FCPA investigation resolved in Feb-2019\. More than enough time has now passed for us to think the SEC is investigating something else. **Maintained on DI Watch List.** ### Inter Parfums, Inc. – IPAR **Undisclosed SEC investigation appears over. Removed from Watch List.** Early signal of a possible SEC investigation received on 26-Jun-2024\. Signal was then confirmed as an ongoing investigation on 19-Aug-2024. Latest signal, dated 26-Feb-2025, suggested an SEC probe was ongoing. However, an appeal response dated 13-May-2025, now suggests SEC investigative activity involving this company is over. File(s) remanded for additional processing and potential release of records. If we learn more, we’ll let you know. **Watch for the lingering internal controls problems:** In early March 2025, the Inter Parfums 10-K was delayed due to internal controls issues. It was then filed on 11-Mar-2025, but the 10-Q filed on 05-May-2025 cautions that, “our material weaknesses will not be considered remediated until the controls operate for a sufficient period of time and management has concluded, through testing, that the related controls are operating effectively.” Here is a summary of the internal controls issues, as disclosed in that NT 10-K filed on 03-March-2025: The Company, in discussion with Forvis Mazars, LLP, has determined that material weaknesses exist with regard to risk assessment, control activities, information technology general controls (ITGCs), and monitoring of its financial reporting. ***\-- John P. Gavin, CFA, NACD.DC*** [Subscribe](#/portal/signup) *This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.* *Our Terms of Service, relevant disclosures, and other legal notices can be* [*found here*](http://www.disclosureinsight.com/)*.* ### CrowdStrike: Restatement Risk Now Elevated URL: https://www.disclosureinsight.com/crowdstrike-restatement-risk-now/ Last updated: 2026-03-17T13:49:13.000Z ***Click here for a printable PDF version of this report.*** [DI Report - Crowdstrike Holdings - CRWD 2025 0612DI Report - Crowdstrike Holdings - CRWD 2025 0612318 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/64bcac8f-e079-4730-b085-2e03552b4034.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### CrowdStrike Holdings, Inc. – CRWD **$ 476.98 US Mkt Cap: $ 116.7 B** ### Summary and Opinion: Last week CrowdStrike first disclosed joint SEC/DOJ probes. We received an early signal of a possible SEC investigation on 17-Jan-2025, and alerted our subscribers shortly thereafter. In May, Bloomberg published a piece reporting the existence of SEC/DOJ probes, highlighting a $32 million Carahsoft transaction with the IRS as a key focus. After reviewing the timeline and parsing the disclosures we believe this situation is likely to worsen before it improves. We conclude restatement risk is now significantly elevated. ### From DI Research: • DI’s Early Signal of SEC probe: 17-Jan-2025 • SEC probe confirmed as ongoing: 24-Apr-2025 • First disclosure of SEC probe: 04-Jun-2025 ### Excerpt From Transcript of CrowdStrike’s Earnings Call on 03-Jun-2025: *Matthew George Hedberg – Analyst, RBC Capital Markets* > Congrats on the results. Not an easy environment for sure. George, I wanted to ask about U.S. Fed. I guess how has it been trending? Sort of what's baked into the guide? And if there's ***any comment that you could make on -- there was a Bloomberg article earlier in May***, that would certainly be helpful. *Burt W. Podbere – CrowdStrike CFO* > So I'll take the second part of your question, any comments with respect to Bloomberg. So for us, the company and how the -- and how Bloomberg reported what they reported, ***the company received request for information from the DOJ and the SEC relating to revenue recognition*** and reporting of ARR for certain transaction -- for certain transactions, the July 19 outage and related matters. ### **From the CrowdStrike 10-Q filed on 04-Jun-2025:** **First disclosure in an SEC filing of SEC/DOJ exposure.** > ***The Company has received requests for information*** from the U.S. Department of Justice and the U.S. Securities and Exchange Commission ***relating to the Company’s recognition of revenue*** and reporting of ARR for transactions with certain customers, the July 19 Incident and related matters. The Company is cooperating and providing information in response to these requests. [Subscribe now](https://www.disclosureinsight.com/subscribe) ### DI's Take: **The July 19th incident could be a distraction and, in our view, is a lesser concern here.** Potential problems with revenue recognition are where we suggest you focus your attention. According to CrowdStrike’s Root Cause Analysis, published in August 2024, the July 19th incident was a software update failure that caused a massive, unintended IT outage. Their greatest risk was at the time it occurred, along with potential litigation and reputational damage. Beyond that, we are not especially concerned about the SEC and DOJ involvement related to this incident nearly a year later. **Here are a few points from the new disclosure of SEC and DOJ investigative activity that should concern you:** - **Our work suggests CrowdStrike has known about an SEC investigation since at least January 2025**, but waited until June to disclose it publicly. You should immediately ask: What changed? What developments prompted this delayed disclosure? In our experience, such changes often indicate the investigation is not going well. - **Revenue recognition problems are the leading cause of restatements.** DOJ and SEC “requests for information” related to revenue recognition was the first item the company disclosed. CrowdStrike did not include this disclosure lightly—they recognize that their revenue recognition practices now represent a material risk. - **Both the SEC and DOJ are involved, which is unusual** outside of Foreign Corrupt Practices Act cases. This dual involvement suggests potential criminal exposure, though the exact reasons remain unclear. - **Internal controls risk:** In that same 10-Q in which we first learned of SEC/DOJ problems, CrowdStrike did tell us internalt controls were effective, as of 30-Apr-2025\. Management made a similar claim in the 10-K filed 10-Mar-2025, effective as of 15-Jan-2025\. That surprised us and could change. An SEC investigation into revenue recognition significant enough to require disclosure almost certainly involves underlying internal control weaknesses. **Finally, a word on management intent.** It appears CrowdStrike aimed to delay disclosure of the SEC/DOJ investigation until after the earnings call. The earnings release and prepared remarks made no mention of the investigation. The disclosure only came in response to an analyst question during the call. We see this pattern of delayed disclosure too often now. It prevents analysts from asking informed questions during the call and signals a company seeking to limit transparency around material risks. ***– John P. Gavin, CFA, NACD.DC*** [Subscribe](#/portal/signup) **Our Terms of Service, relevant disclosures, and other legal notices** [**can be found here**](http://www.disclosureinsight.com/)**.** ### DI's Early Signals Report: June 09, 2025 URL: https://www.disclosureinsight.com/dis-early-signals-report-june-09/ Last updated: 2026-03-17T13:49:13.000Z ***Click on the PDF here to access a printable version of this report.*** [DI's Early Signals Report: June 09, 2025DI's Early Signals Report: June 09, 2025298 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/b7341d6f-ba32-46a9-b352-f8e9d75f0f80.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What’s an Early Signal? DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation “confirmed” after we file an administrative appeal and have received a response that says as much. **Important:** The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security. In its responses, the SEC did not disclose the details on investigative activity referenced herein. All we know is that they somehow pertain to the conduct, transactions, and/or disclosures of the companies. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. 2. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 3. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 4. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. **All-access clients are welcome to contact us anytime to learn more.** [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### DI Watch List - June 04, 2025 URL: https://www.disclosureinsight.com/di-watch-list-june-04-2025/ Last updated: 2026-03-17T13:49:13.000Z #### ***You need to click on the printable PDF below to access the full DI Watch List.*** [DI Watch List - June 04, 2025DI Watch List - June 04, 2025760 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/36efc2d0-3564-4c07-8fd6-7457f9ed0e5f.pdf "Download") **We are currently tracking 119 companies** with confirmed, and ongoing undisclosed SEC investigations. Going all the way back to 2000, this is the largest number of undisclosed SEC investigations of public companies we’ve ever found. **Last September, 2024, we were only tracking 77 companies on our Watch List.** This isn’t because I suddenly decided to work harder. The increase is solely a function of what DI’s FOIA research is uncovering. **I don’t yet know what this all means.** Trump 45 had a very light touch with the SEC. Aside from nearly every crypto investigation being shut down, it’s too early in Trump 47’s term to make sense of a 54% increase in SEC investigative activity at public companies since last autumn. The backlog of research-in-process also remains one of the biggest we’ve ever seen. Those reports will keep coming out in June. All I can do at this point is alert you to this change and promise I’m paying close attention. As a reminder, Disclosure Insight is an independent research provider focused solely on public company interactions with the SEC. We’ve been at it since 2000, consistently delivering expertise no one on Wall Street can match. **If you’re a professional interested in learning more about our all-access service level, feel free to email or call me.** No matter your service level, my goal is to help you make money and, above all, avoid losses. **Please tell others.** You can even forward this report to whoever you like. As always, I thank you for your support. *\- John* **John P. Gavin, CFA, NACD.DC** [Subscribe now](https://www.disclosureinsight.com/subscribe) *When we alert you to existence of an undisclosed SEC probe, that means we filed a Freedom of Information Act (FOIA) request with the United States Securities and Exchange Commission (SEC) on the company in question and have a response, in black-and-white, on government letterhead that supports our statement. The only thing we know at this time is that the investigation(s) somehow pertains to the conduct, transactions, and/or disclosures of the companies referenced.* [Subscribe](#/portal/signup) ### SEC Investigation Updates - May 28, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-may-28/ Last updated: 2026-03-17T13:49:14.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - May 28, 2025SEC Investigation Updates - NF - May 28, 2025285 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/9af29fa7-890f-437a-ba10-dca32955ca2a.pdf "Download") [Subscribe](#/portal/signup) ### SEC Investigation Updates: May 21, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-may-21/ Last updated: 2026-03-17T13:49:14.000Z **All-access clients are welcome to contact us anytime to learn more.** ## Today’s report - - **AutoNation, Inc. - AN** - **Broadcom, Inc. - AVGO** - **CBIZ, Inc. - CBZ** - **Cisco Systems, Inc. - CSCO** - **International Paper Co. - IP** - **Procter & Gamble Company, The - PG** - **SentinelOne, Inc. - S** - **ZoomInfo Technologies, Inc. - ZI** ***Click on the PDF here to access a printable version of this report.*** [SEC Investigation Updates - May 21, 2025SEC Investigation Updates - May 21, 2025314 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/a9f5ee71-4a28-481c-b5ab-736319ef52d0.pdf "Download") ## COMPANY COMMENTS ### AutoNation, Inc. – AN **Warning Reiterated – SEC investigation again confirmed as ongoing.** Earliest signal of undisclosed SEC investigative activity first found at AutoNation on 17-Jul-2023\. Enforcement proceedings now confirmed as ongoing three times since, most recently on 02-May-2025\. A cyber incident in June 2024 could have triggered its own SEC investigation, but our early signal came a full year earlier, in Jul-2023, suggesting whatever we've been tracking since then has nothing to do with it. **Maintained on DI Watch List.** ### Broadcom, Inc. – AVGO **Warning Reiterated – Two undisclosed SEC investigations now identified, one remains ongoing.** Early signal of a possible SEC investigation received on 29-Mar-2024\. Enforcement proceedings now confirmed as ongoing two times since, most recently on 08-May-2025\. In this same May-2025 response, the SEC told us of two SEC investigations here; only one is remains ongoing. **Maintained on DI Watch List.** ### CBIZ, Inc. – CBZ **Warning Reiterated – Three undisclosed SEC investigations now identified, one remains ongoing.** Early signal of undisclosed SEC investigative activity first found on 11-May-2023, now confirmed as ongoing two times since, most recently on 02-May-2025\. In its May-2025 response, the SEC told us of three SEC investigations here; only one remains ongoing. **Maintained on DI Watch List.** ### Cisco Systems, Inc. – CSCO **New Warning.** Early signal of a possible SEC investigation received on 08-Jan-2025\. Signal was then confirmed as an ongoing investigation on 02-May-2025 This is consistent with responses dated between Feb-2023 and May-2024, when we knew there was a FCPA investigation involving China which the company said was over. Over time we found Cisco has a history of hiding things from you. Make sure to ask if there are any other SEC investigations you have not been told about. **Added to DI Watch List.** ### International Paper Co. – IP **New Warning.** Early signal of a possible SEC investigation received on 08-Jan-2025\. Signal was then confirmed as an ongoing investigation on 02-May-2025. **Busy Guy – Watch out for this highly unusual arrangement:** Andy Silvernail, Chair and CEO of International Paper, also serves as the Audit Committee Chair for Stryker Corporation (SYK). This is rare, given that the Audit Committee is widely considered the most time-intensive board committee. International Paper initially disclosed his audit chair position at Stryker when he became CEO in Mar-2024\. But the Sep-2024 announcement of his additional role as Chairman only noted his membership on the Stryker board, leaving out his continued audit chair responsibilities. Stryker’s appointment of a new CFO effective in Apr-2025, will further increase the Audit Committee’s workload – and distraction for Mr. Silvernail. **Added to DI Watch List.** [Subscribe now](https://www.disclosureinsight.com/subscribe) ### Procter & Gamble Company, The – PG **Warning Reiterated – SEC investigation again confirmed as ongoing**. Early signal of a possible SEC investigation received on 07-Mar-2024\. Enforcement proceedings confirmed as ongoing two times since, most recently on 02-May-2025\. **Maintained on DI Watch List.** ### SentinelOne, Inc. – S **Warning Reiterated – SEC investigation again confirmed as ongoing.** Early signal of a possible SEC investigation received on 29-Apr-2024\. Enforcement proceedings confirmed as ongoing two times since, most recently on 08-May-2025\. Ask if the SEC is investigating matters raised in the Fortis litigation. **Fortis litigation:** In the 10-Q filed 05-Dec-2023, SentinelOne disclosed litigation in which the plaintiff, Fortis, claims the company’s SEC filings allegedly contained materially false or misleading statements about its annual recurring revenues. The case is captioned *Fortis Advisors LLC v. SentinelOne, Inc., Case No. 2023-0946-VLM.* **Maintained on DI Watch List.** ### **ZoomInfo Technologies, Inc. – ZI** **Undisclosed SEC Investigation Appears Over.** Early signal of undisclosed SEC investigative activity first found on 10-Jul-2023, then confirmed as ongoing twice, most recently on 12-Jun-2024\. Latest signal, 17-Jan-2025, suggested an SEC probe was ongoing. However, an appeal response dated 02-May-2025, now suggests SEC investigative activity involving this company is over. File(s) remanded for additional processing and potential release of records. If we learn more, we’ll let you know. **Removed from DI Watch List.** ***\-- John P. Gavin, CFA, NACD.DC*** [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### SEC Investigation *Alerts* URL: https://www.disclosureinsight.com/sec-investigation-alerts/ Last updated: 2026-03-17T13:49:14.000Z **This is a new report format.** We will use this “Alerts” format to warn you about events and updates that, in our opinion, raise the risk on companies where we previously found possible or confirmed, undisclosed SEC investigations. **Today’s report includes alerts typical of those you can expect going forward** — - Two companies with general counsel departures on short or no-notice; - Delayed filing on a company we warned had tried to bury an SEC investigation in Forward Looking Statements; - Auditor change; and, - A recent deal that could be impacted by undisclosed SEC investigative activity at both companies. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/fe36ec24-72a6-4728-90eb-f520024ebf9c_726x469-1.png) **All-access clients are welcome to contact us anytime to learn more.** [SEC Investigation Update - Alerts - May 20, 2025SEC Investigation Update - Alerts - May 20, 2025312 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/0ebc4fe8-e0ab-4429-8ad3-d76a3d343dfe.pdf "Download") - ***Click on the PDF here to access a printable version of this report.*** [Subscribe now](https://www.disclosureinsight.com/subscribe) ### Arista Networks, Inc. – ANET **Event: Abrupt departure of the general counsel** Per Arista Networks 8-K filed 06-May-2025: On 01-May-2025, Marc Taxay, Arista’s General Counsel, notified the company of his intention to resign effective 07-May-2025. Arista gave us the fluff-and-spin that the general counsel’s decision to leave was not the result of any disagreement with the company, and they wished him well. No explanation otherwise given for the sudden departure. The abrupt departure of a C-Suite executive, especially in the presence of an undisclosed SEC investigation is a red flag. **Arista Networks is on the DI Watch List.** We’ve been tracking an undisclosed SEC investigation at the company since 27-Aug-2024, last confirmed as an ongoing investigation on 18-Dec-2024. ### DICK’S Sporting Goods – DKS Foot Locker, Inc. – FL **Event: Confirmed, undisclosed SEC investigation at Foot Locker, and a possible SEC investigation at DICK’S Sporting Goods** adds risk to the recently announced deal. On 15-May-2025, DICK'S Sporting Goods announced its planned acquisition of Foot Locker. The deal is expected to close in the second half of 2025. **Footlocker is on the DI Watch List.** We have been tracking an undisclosed SEC investigation at Foot Locker since 12-Feb-2024, confirmed as ongoing on 29-May-2024\. Our latest signal on Foot Locker, dated 06-Jan-2025, suggests that SEC probe was still ongoing. We are awaiting confirmation of this latest signal. **Early signal of a possible SEC investigation at DICK’s** received on 16-Apr-2025\. We are awaiting confirmation of this signal. ### New Fortress Energy, Inc. – NFE **Event: 10-Q now delayed, including resignation of Chief Accounting Officer**, a month after we warned New Fortress was trying to hide an SEC investigation. On 10-Apr-2025, at $6.68 / share, we published a warning on New Fortress Energy, calling it a company playing Disclosure Games® for trying to bury an SEC investigation within forward-looking statements. **Now the 10-Q is delayed.** The NT 10-Q was filed on 13-May-2025\. The company partially blamed this on the resignation of the Chief Accounting Officer, effective 29-Apr-2025. Further, that stealth language that was warned about earlier – below – is now missing from the Forward Looking Statements. The missing language – **SEC investigation as previously cited in Forward Looking Statements**, 8-K filed on 27-Mar-2025: > Specific factors that could cause actual results or events to differ from those in the forward-looking statements include, but are not limited to … the impact of regulation and regulatory, investigative and legal proceedings and legal compliance risks, ***including the impact of SEC and other investigative and legal proceedings.*** **New Fortress Energy is on the DI Watch List.** We’ve been tracking an undisclosed SEC investigation at the company since 11-Dec-2024, last confirmed as ongoing investigation on 06-Mar-2025. ### Quanterix Corp. – QTRX **Event: Auditor Change** On 09-May-2025, Quanterix appointed KPMG to replace Ernst & Young. Wide array of problems found, back to 2022, including internal controls issues and C-suite turnover. The board chair resigned abruptly on 24-Mar-2025, after failure to receive enough votes at the annual meeting. Now an auditor change. Maybe the board, such as it is, grew tired of those adverse opinions the former auditor kept issuing. **Quanterix is on the DI Watch List.** We’ve been tracking an undisclosed SEC investigation at the company since 17-May-2024, last confirmed as ongoing investigation on 16-Aug-2024\. New research in-process as of Feb-2025. ### Roku Inc. – ROKU **Event: Departure of the general counsel on short notice** Per 8-K filed 07-May-2025: On 01-May-2025, Louise Pentland, General Counsel of Roku, notified the company of her decision to resign, effective 16-May-2025\. The company said she’s leaving “to pursue another opportunity." The departure of a C-Suite executive, especially in the presence of an undisclosed SEC investigation, is a red flag. The only way this one could be worse is if the departure was abrupt, as in same-day, with no reason given. **Roku is on the DI Watch List.** We’ve been tracking an undisclosed SEC investigation at the company since 09-Dec-2024, last confirmed as an ongoing investigation on 06-Mar-2025. ***\-- John P. Gavin, CFA, NACD.DC*** [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### SEC Investigation Updates - May 15, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-may-15/ Last updated: 2026-03-17T13:49:14.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - May 15, 2025SEC Investigation Updates - NF - May 15, 2025287 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/de8936d5-f1c8-42e8-bdd1-9a2e70cb76b9.pdf "Download") [Subscribe](#/portal/signup) ### DI's Early Signals Report: May 14, 2025 URL: https://www.disclosureinsight.com/dis-early-signals-report-may-14-2025/ Last updated: 2026-03-17T13:49:15.000Z ***Click on the PDF here to access a printable version of this report.*** [DI's Early Signals Report: May 14, 2025DI's Early Signals Report: May 14, 2025297 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/c5d47991-43fa-4f5b-95bf-51b1047ad844.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What’s an Early Signal? DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation “confirmed” after we file an administrative appeal and have received a response that says as much. **Important:** The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security. In its responses, the SEC did not disclose the details on investigative activity referenced herein. All we know is that they somehow pertain to the conduct, transactions, and/or disclosures of the companies. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. 2. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 3. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 4. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. **All-access clients are welcome to contact us anytime to learn more.** [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### DI's Early Signals Report: May 07, 2025 URL: https://www.disclosureinsight.com/dis-early-signals-report-may-07-2025/ Last updated: 2026-03-17T13:49:15.000Z ***Click on the PDF here to access a printable version of this report.*** [DI's Early Signals Report: May 07, 2025DI's Early Signals Report: May 07, 2025304 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/5a614335-798c-440f-b197-549a9b62ef57.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What’s an Early Signal? DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation “confirmed” after we file an administrative appeal and have received a response that says as much. **Important:** The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security. In its responses, the SEC did not disclose the details on investigative activity referenced herein. All we know is that they somehow pertain to the conduct, transactions, and/or disclosures of the companies. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. 2. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 3. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 4. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. **All-access clients are welcome to contact us anytime to learn more.** [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### SEC Investigation Updates - April 29, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-april-29/ Last updated: 2026-03-17T13:49:15.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - April 29, 2025SEC Investigation Updates - NF - April 29, 2025318 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/2de9fe9c-5c29-4b0b-b8cb-7c4c447f6cf8.pdf "Download") [Subscribe](#/portal/signup) ### It's Too Late: Your Ship's Not Coming In URL: https://www.disclosureinsight.com/its-too-late-your-ships-not-coming/ Last updated: 2026-03-17T13:49:17.000Z ## From John’s Desk … *“You will not find it difficult to prove that battles, campaigns, and even wars have been won or lost primarily because of logistics.”* – Dwight D. Eisenhower ### We’ve crossed the Rubicon on tariffs. **The shipping data are undeniable: the ships aren’t coming in.** Like a lava flow, there’s no stopping what’s headed our way – or, more precisely, no quick way to replace what’s *not* coming. Cargo vessels arriving at U.S. ports – especially in California, where most imports from Asia land – have declined sharply and are expected to get worse. The die is cast. There’s no turning back, at least not quickly. If you haven’t started stocking up on essentials yet, now’s the time. Batteries, seriously. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/eb8662f0-b002-417f-ae61-f3b7d9245ecd_544x537-1.webp) Sure, markets continue to cheer every morsel of “tariff hopeium” from the White House – those recurring, always-optimistic promises of trade breakthroughs. But logistics experts, industry leaders, and supply chain pros have been sounding the alarm for weeks. Their message is consistent, well supported by easily observable data, and has grown more urgent: We’re facing supply chain disruptions on a scale not seen since the pandemic – and likely worse. **How can the stock market thrive if warnings of severe supply chain disruptions come to fruition?** It can’t and it won’t. We have some rough water ahead. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/b307427d-dc3c-4498-b8f7-999a05d95a85_777x268.png) ### So what’s going on? **Uncertainty over tariffs has caused businesses to dramatically reduce or stop ordering products from overseas.** In the unlikely event the president fully reverses his ill-advised posture on tariffs, one expert recently told *Fortune* it would take two months for supply chains to be restored from here. Others have said much longer, depending on the products and factories that produce them. > “Even if the president said, ‘Oh, this was for nothing; we’re going to stop the trade war; everything’s back to normal,’ it’ll still take two months for things to get back to normal.” *Dean Croke, principal analyst for freight data and analytics at DAT, told Fortune.* **Trucking and land-based freight are already slowing sharply.** The disruption goes beyond ships sitting offshore – or not sitting offshore, as is our growing problem. Container traffic at the Port of Los Angeles, the nation’s busiest, has dropped about 20% year-over-year, with industry insiders warning the worst is yet to come. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/b2af52a4-c5c9-426b-a9d7-80d65f37e83e_617x368.webp) **How are you supposed to plan or price your products?** You own a business importing heavily from China, where today’s tariff of 145% could suddenly drop to 10% tomorrow with a late-night tweet. Businesses are stuck, scrambling for costly workarounds instead of doing what they do best; you know, running their operations and making money. Social media is full of videos showing distressed small business owners fearful they may have no choice but to close their companies. Some said they will simply close shop, abandoning shipments at the dock - an added complexity to the logistics mess. Soon. [Subscribe now](https://www.disclosureinsight.com/subscribe) ### These aren’t just sob stories. Small businesses employ nearly half the U.S. workforce and contributes roughly 44% of GDP. In April, PYMNTS Intelligence posted a report that 1 in 5 smaller businesses without financing may not survive tariff-related pressures. This is the type of economic and social harm that could last for years. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/4b8b08f0-a2ca-42b1-89b9-0c87141c29a4_713x241.png) **It appears they have no plan.** At this point, the president and his team can say or do whatever they want on trade. They can tout the brilliance of their strategy, and continue to promise “deals” are imminent. Some of that may even be true. But none of it changes this stubborn fact: It appears they have no plan. No key metrics have been provided to let us measure the supposed success of the new tariffs regime. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/f7e8a81b-9afa-4c69-90f8-a633606dd356_648x176.webp) ### Business people are past talk – they need results. Instead, they get an administration that appears to be making it up as they go along, resulting in mixed messaging that confuses markets and businesses alike. Worse, those across the trade negotiating table see it clearly and are exploiting it to our disadvantage. **Experts warn shelves will start getting thinner as soon as early summer**, with back-to-school season especially at risk. The Christmas shopping season will have a whole different feel to it if tariff pressures aren’t eased next month. The month of May is when most retailers need to place their orders for holiday merchandise to have it arrive in time. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/ef23b453-46b4-472d-9042-102d566db5a6_560x390.png) **Unrelated but equally concerning, student loan collections resume in May.** There are over 5 million Americans already in default, with millions close behind. People need to repay their debt, and failure to enforce that creates its own set of problems. However, these consumers will soon face threats of wage garnishments and tax refund seizures just as tariff-driven price increases ripple through the economy. Housing, auto loans, travel, and other sizable economic drivers are also showing troubling signs. All these pressures are converging simultaneously. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/b317b6b9-bf4d-4417-9b9b-08bc3326fa8f_607x155.png) **As for markets?** Traders love volatility, so markets will keeping taking the bait – until they won’t. As I’ve said throughout my investing career, opportunities exist in every market environment. Eventually, more great companies and assets will likely go on sale in the coming months, many at fire sale prices. Watch for them. Your next inflection point will likely come when nightly news is filled with stories of empty shelves, layoffs, business closures, and angry consumers. **A final, personal observation:** Like many who make their way in life, I grew up in a working class family that lived on the edge financially. As a volunteer first responder, for decades I went into the homes of people doing the same. As a business owner, 50 of the employees from a company it took me a decade to build all lost their jobs in one fell swoop when our primary financial supporter had its own problems and backed away. I know the grittier side of our economy because I’ve lived it. These are my people from where I came. They are the people who truly make this country great. Thanks to tenacity, hard work, and the opportunities available growing up, the analyst in me can now look ahead at possible investments I can make. But that working class kid in me looks ahead with dread and concern over a disaster of our own making. Congress holds the constitutional authority to regulate foreign commerce and impose tariffs. It’s well past time they assert it. For now, batten down the hatches. And stock up on batteries and other things you might need while you can. There’s no stopping the storm that’s about to hit. *\- John* **John P. Gavin, CFA, NACD.DC** [Subscribe](#/portal/signup) ### SEC Investigation Updates - April 24, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-april-24/ Last updated: 2026-03-17T13:49:17.000Z [Subscribe now](https://www.disclosureinsight.com/subscribe) ## Today’s report - - **Carvana Co. - CVNA** - **Freedom Holding Corp. - FRHC** - **Malibu Boats, Inc. - MBUU** ***Click on the printable PDF here to access this report.*** [SEC Investigation Updates - April 24, 2025SEC Investigation Updates - April 24, 2025310 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/58687f89-a646-470c-9bbf-e12ea406f097.pdf "Download") [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### DI's Early Signals Report: April 23, 2025 URL: https://www.disclosureinsight.com/dis-early-signals-report-april-23/ Last updated: 2026-03-17T13:49:18.000Z ***Click on the PDF here to access a printable version of this report.*** [DI's Early Signals Report: April 23, 2025DI's Early Signals Report: April 23, 2025296 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/85528ed1-f5ea-40c2-a37d-7337b7069f21.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What’s an Early Signal? DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation “confirmed” after we file an administrative appeal and have received a response that says as much. **Important:** The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security. In its responses, the SEC did not disclose the details on investigative activity referenced herein. All we know is that they somehow pertain to the conduct, transactions, and/or disclosures of the companies. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. 2. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 3. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 4. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. **All-access clients are welcome to contact us anytime to learn more.** [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### Everything and the Kitchen Sink URL: https://www.disclosureinsight.com/everything-and-the-kitchen-sink/ Last updated: 2026-03-17T13:49:18.000Z ### *From John's Desk …* It’s finally spring here in Minnesota and that bee lawn I planted last fall is showing early signs of emerging. Good. I’m excited to see how it turns out. Let’s get to it. ### Earnings and Valuation Challenges **Thanks to tariffs, expect upcoming earnings seasons to include everything *and* the kitchen sink – a lot of kitchen sinks.** Bad in the near term, potentially great a year or so from now when we’re doing our year-over-year comparisons. This is a gift for companies with some detritus on their books they need to clean up. Now they can do so without anyone the wiser. You know, because of tariffs. Remember something similar a few years ago? Covid. Many companies reported light earnings, you know, because of the pandemic. During these periods there will be no way to verify whether what the companies are telling you is true. Doesn’t matter, it’s still going to happen. After this current earnings season, which has no tariff impact on the reported results for anyone, get ready for a tariffs overhang for at least the balance of 2025. ![A cartoon of a kitchen sink with a plant on the top. | Premium AI ..., image size:626x351](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/a58383ce-424c-4e1b-b875-ae367c36031d_626x351-jpeg-1.jpg) **How do you make money/avoid losses in this environment?** As quality companies go on sale, there will be plenty of ways to make money. I do love buying things on sale! I will post on one of these ideas soon. As for avoiding losses, one thing that could help is following our warnings on undisclosed SEC investigations. Another is to see if there were any recent comment letters exchanged. Those can contain an abundance of analytically-rich material that can signal trouble ahead. Finally, watch for recent and meaningful board or C-suite turnover. Few companies will be immune to some kind of pressure because of tariffs. Those that have underlying SEC investigations or recent comment letter challenges are especially vulnerable, if only because they were already distracted by the investigative activity or comment letter requirements. Directors and senior level execs are scrambling for information amidst tariff uncertainty. This is not the ideal time for a new group to be getting to know each other. **Valuation Forecasts – Ignore That Noise Too:** Already seeing lots of forecasts out there, trying to give us a sense of how low the market can go (I’ve been around long enough to have lived it – markets can go much lower). Ignore that noise, at least for now. Here’s why: The ‘E’, earnings portion of ‘PE’ is both unreliable and unpredictable at this time, rendering your forecast useless, if not overstated. This week I saw some estimates that the S&P 500 could see about 7% earnings compression from tariffs. Really? Do you believe tariffs will only hurt earnings by just 7%? Feels too low. > **Side note**: Last week David Trainer of [**New Constructs Research**](https://www.newconstructs.com/?ref=disclosureinsight.com) had me as a guest on his monthly podcast. We talked about Disclosure Insight’s research process, changes at the SEC, along with a few tips and tricks you can use. [**You can listen to it here**](https://www.youtube.com/watch?v=eLkI7zaQ06M&ref=disclosureinsight.com). I start talking about 9 minutes in. > > Need a guest on your podcast or speaker at your event? Feel free to reach out. My style is fact-based, yet irreverent and entertaining. We’ll have a good time. ### SEC Update Earlier, I warned of the heightened risk to markets with the SEC now reporting to the White House, its independence having been removed via executive order over the winter. For those who missed it, [*With Its Independence Removed, the SEC is Now Being Rapidly Dismantled*](https://www.disclosureinsight.com/p/with-its-independence-removed-the)*.* Despite DOGE pressure and staff reductions, FOIA requests and replies are still flowing well. However, here’s two ways the SEC’s reporting to the White House is already having a negative impact – 1. **Good luck with that.** After widespread accusations were made of possible insider trading last week ahead of Trump’s announcement of a 90 day pause on tariffs, Democrats called for the SEC to investigate the same. The trading patterns do look suspect, and under an independent SEC, such an investigation would likely take place. I think there’s about zero chance that happens now. That’s bad. Letting suspicious trading go unexamined erodes confidence in markets. It also does nothing to deter repeat offenders. 2. **Crypto bros still loving this new SEC they got for their money.** It’s well documented that the crypto industry was a heavy donor to Trump during and since the campaign. The family itself is knees deep into all kinds of things crypto (we’ll just look past those pesky, yet glaring conflicts-of-interest).Yet in the midst of a global financial storm triggered by Trump’s tariffs announcements, we get this tweet from the SEC, at a highly unusual time, 11 am, on a Saturday morning, April 5th – ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/0a77b7b8-85a7-444e-ba6a-aed902365d8a_624x176.png) There were six “staff statements” the Acting SEC Chair requested “Commission staff to promptly review”. Five of the six are crypto related. For an agency that’s been around since the 1930s, surely you’d think there are multiple ways for, “unleashing prosperity” that don’t involve crypto. To this, I tweeted the following in reply – ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/06eea28a-c34e-4877-bed5-4396b99c08fd_612x312.png) With so many of its crypto investigations now shut-down, and a regular stream of tweets from the SEC related to crypto, one cannot help but wonder if this SEC tweet was written for an audience of one: Donald Trump. Now how does that protect investors? [Subscribe now](https://www.disclosureinsight.com/subscribe) ### We End With a Random Thought … **What happens if a lot of people abandon shipments at the dock?** It’s not hard to find videos of small business owners in a panic over tariffs, especially those with shipments inbound from China. Unlike the large companies that can better manage this expense and disruption, many of these smaller companies say they can’t pay the inflated tariffs and are likely to just close their companies, abandoning their orders at the dock. Imagine that starts happening at scale. **Could these abandoned shipments start stacking up so badly that the ports can’t handle it, potentially disrupting supply chains across the country?** The biggest inbound ports for items from China and Asia are the two in the Los Angeles area. Watch this space. This could have impact in ways no one’s expecting. Who can make money off docks stacked high with abandoned shipments? ### Coming Up: Last week I attended a joint meeting that my local chapter of the National Association of Corporate Directors held with the local investor relations chapter. I also attended an SEC update webinar hosted by Intelligize, which was aimed at public company accounting and legal people. I have some good takeaways I’ll share next time. Lastly, while everyone else is watching the yield on 10-year Treasuries, I’m paying closer attention to the spread between high yield credits and treasuries. You can potentially make boatloads of money if things get extreme with high yield credits. I’ll have a brief note coming out soon that will explain how. That’s all I got for now! Let’s be careful out there. *\- John* **John P. Gavin, CFA, NACD.DC** ### Disclosure Games: Wait 'Til You See Where This SEC Investigation Was Buried URL: https://www.disclosureinsight.com/disclosure-games-wait-til-you-see-2/ Last updated: 2026-07-03T18:02:04.000Z *A printable PDF version of this report appears at the bottom.* ### See that tiny print highlighted in the image below? Below is an excerpt from an 8-K filed 27-Mar-2025 by New Fortress Energy. Specifically, it’s the entirety of the text from the Forward Looking Statements portion of the 8-K. As any seasoned investor knows, Forward Looking Statements are widely viewed as boilerplate language that no one ever reads. It’s also where New Fortress Energy buried an SEC Investigation. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/07/a363aabd-8679-4927-8b2a-f20bec90d483_673x228.png) The language highlighted above is so tiny you can’t read it here, and most people surely didn’t even bother to try when they came across it in the 8-K. Here’s what it says – > Specific factors that could cause actual results or events to differ from those in the forward-looking statements include, but are not limited to: … the impact of regulation and regulatory, investigative and legal proceedings and legal compliance risks, **including the impact of SEC and other investigative and legal proceedings;** These people are playing Disclosure Games®. That text highlighted above is brand new. A search of the company’s SEC filings, back to the 8-K filed 28-Feb-2023, otherwise found no clear disclosure of SEC investigative activity. In well over 25 years of reviewing SEC filings, the only other time we saw this stunt was over ten years ago, when Hertz Global Holdings (HTZ) did the same thing, in an 8-K filed on 04-Nov-2014\. Ten days later, on 14-Nov-2014, Hertz more clearly disclosed an SEC investigation on which it gave no detail. #### **DI’s Research:** **In our research,** an early signal of a possible SEC investigation was received on 11-Dec-2024\. Signal was then confirmed as an ongoing investigation on 06-Mar-2025\. This is a change from a response dated 16-Jan-2024, at which time no signs of ongoing SEC investigative activity were found. As we said above, a search of SEC filings, back to the 8-K filed 28-Feb-2023, found no clear disclosure of SEC investigative activity. We have no documents or meta-data from closed SEC probe(s) of this company. This is the first sign of an SEC investigation we found since we started covering New Fortress Energy in Mar-2023. #### Notable Items: **10-K delayed, NT 10-K filed on 04-Mar-2025:** > The Company requires additional time to complete its financial statement preparation and review process. In addition, the Company requires additional time in order to reflect certain financing transactions which will support the Company's obligations and debt service and are expected to close in the near term. **SEC investigation cited in Forward Looking Statements, 8-K filed on 27-Mar-2025:** > Specific factors that could cause actual results or events to differ from those in the forward-looking statements include, but are not limited to … the impact of regulation and regulatory, investigative and legal proceedings and legal compliance risks, including the impact of SEC and other investigative and legal proceedings; #### DI's Take: The lawyers clearly felt the risk from the SEC investigation we found was high enough that something had to be disclosed. However, someone at the company made the choice to obscure this information, burying it in a location unlikely to attract attention. You decide. Is this a company worthy of your capital? Our work suggests New Fortress Energy may have known about an SEC probe since at least Dec-2024\. Given this, and the new language buried in the Forward Looking Statements, that delayed 10-K in Mar-2025 takes on added meaning now. ***– John P. Gavin, CFA, NACD.DC*** [Subscribe now](https://www.disclosureinsight.com/subscribe) *“Disclosure Games®” is a term we use to highlight those public companies engaging in disclosure practices that in our opinion may be misleading, confusing, evasive, or otherwise lacking the transparency needed for investors to make well-informed investment decisions regarding a potentially material exposure.* **For reasons outlined in this report, we have identified New Fortress Energy as a company playing Disclosure Games.** [DI Report: Wait 'Til You See Where This SEC Investigation Was Buried - New Fortress Energy (NFE)DI Report: Wait 'Til You See Where This SEC Investigation Was Buried - New Fortress Energy (NFE)393 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/ae8d2644-11ef-470b-9fc9-f0088dd324ca.pdf "Download") [Subscribe](#/portal/signup) **To learn more about our research process, including how to best use this information in your own decision-making,** [**click here**](https://probesreporter.com/our-research-process?ref=disclosureinsight.com)**.** **Our Terms of Service, relevant disclosures, and other legal notices** [**can be found here**](https://probesreporter.com/legal?ref=disclosureinsight.com)**.** ### SEC Investigation Updates - April 08, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-april-08/ Last updated: 2026-03-17T13:49:19.000Z [Subscribe now](https://www.disclosureinsight.com/subscribe) ## Today’s report - - **Advanced Micro Devices, Inc. - AMD** - **Brandywine Realty Trust - BDN** - **Emerson Electric Co. - EMR** - **Microchip Technology Inc. - MCHP** - **Tetra Technologies, Inc. - TTI** - **TriCo Bancshares - TCBK** ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - April 08, 2025SEC Investigation Updates - April 08, 2025314 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/37a74098-3baa-46ec-ba89-feb140fd8fd2.pdf "Download") [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### DI's Early Signals Report: April 04, 2025 URL: https://www.disclosureinsight.com/dis-early-signals-report-april-04/ Last updated: 2026-03-17T13:49:19.000Z ***Click on the PDF here to access a printable version of this report.*** [DI's Early Signals Report: April 04, 2025DI's Early Signals Report: April 04, 2025304 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/2e4333cf-778c-4d2f-88dc-6027f82e794d.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What’s an Early Signal? DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation “confirmed” after we file an administrative appeal and have received a response that says as much. **Important:** The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security. In its responses, the SEC did not disclose the details on investigative activity referenced herein. All we know is that they somehow pertain to the conduct, transactions, and/or disclosures of the companies. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. 2. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 3. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 4. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. **All-access clients are welcome to contact us anytime to learn more.** [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### John's Desk: Investors Are Starting to Notice URL: https://www.disclosureinsight.com/johns-desk-investors-are-starting/ Last updated: 2026-03-17T13:49:20.000Z ### *From John’s Desk …* ***"Corruption, embezzlement, fraud, these are all characteristics which exist everywhere ... What successful economies do is keep it to a minimum."*** **\- Alan Greenspan**, in an an interview, September 24, 2007 ## Get Out of Jail Week for the Convicted Fraudsters—both convicted and under investigation—are walking free, thanks to SEC case closures and a flurry of presidential pardons. Investors are starting to notice, with many voicing their displeasure over what they see. This is moving faster than expected when I warned about this very risk in my piece published a couple weeks ago, [With Its Independence Removed, the SEC is Now Being Rapidly Dismantled.](https://www.disclosureinsight.com/p/with-its-independence-removed-the) **Donald Trump’s surprise pardon of Trevor Milton**, of Nikola fame, **angered investors last week**. On the Twitter machine, I noticed the outrage and disgust over this pardon was coming from both sides of the political aisle. Clearly, Milton’s pardon did not land well on Wall Street. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/2836a147-6618-40ae-931e-fe07659c5ad7_961x665-2.png) > **Trevor’s Take:** Taking no accountability for his actions,Trevor uses the word ‘misunderstanding’ a lot in this [**clip from a Wall Street Journal interview**](https://www.wsj.com/video/series/on-the-news/nikola-founder-trevor-milton-details-call-with-trump-ahead-of-pardon/D5E29DCA-698D-45C4-80C6-D51A759A0A0F?ref=disclosureinsight.com) the day after receiving his pardon. > > **John’s Take:** Trevor Milton is the poster child for the danger capital markets now face from donor influence and political meddling. A lot of investors, of all political leanings, are upset about this pardon. Few are buying his "I'm a victim" noise. They don't like seeing fraudsters cut loose. Neither do I, and we’re having an abundance of them right now. With its independence recently removed, and the SEC now reporting up to the White House, we can expect there will be others. ### It’s Not Just Trevor Milton Getting Cut Loose Since Inauguration Day in January, the President has issued pardons or commutations in his second term for six people convicted of financial or fraud-type crimes. Five of them took place just last week. #### Just this past week - - - **Trevor Milton:** Nikola Corporation founder, convicted in 2022 for misleading investors about hydrogen truck technology. Was sentenced to 4 years in prison and a $1 million fine in 2023\. He had yet to report to prison at the time of his full pardon on March 27, 2025. - **The three co-founders of the BitMEX cryptocurrency exchange:** In 2022, all pled guilty to violating anti-money laundering and related rules. All three received probation, with one receiving six months home confinement. Each also had to pay a $10 million fine. All three pardoned fully on March 27, 2025. - **Carlos Watson:** Ozy Media co-founder, convicted in 2024 for defrauding investors of over $60 million. On the very day he was to report to prison, March 28, 2025, Trump commuted his 116-month sentence to time served. > **Side note**: Last week Edwin Dorsey of [**The Bear Cave**](https://thebearcave.substack.com/) hosted me for a Twitter Spaces interview. We talked about Disclosure Insight’s research process, changes at the SEC, along with a few tips and tricks you can use. [**You can listen to it here**](https://x.com/i/spaces/1mnxegDOMnrGX?ref=disclosureinsight.com). > > Need a guest on your podcast or speaker at your event? Feel free to reach out. My style is fact-based, yet irreverent and entertaining. We’ll have a good time. [Subscribe now](https://www.disclosureinsight.com/subscribe) ### Crypto Bros Still Celebrating Too After having heavily donated to the Trump campaign, the crypto bros are loving this new SEC they got for their money. Under new leadership, the SEC wasted no time in shutting down a wide array of investigations in that space and promised a light touch on things crypto going forward. Even as recently as last week, SEC investigations of possible securities fraud at crypto companies continued to be closed without further action. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/b7f781c3-edb5-491f-8abc-3fd79c1a7777_712x463.webp) This change in emphasis is not out of the ordinary when a new president comes into office. New president, new priorities. Everyone knows the rules. **But are we throwing out the baby with the bathwater?** Under what appears to be an, “all crypto investigations bad” standard at the SEC, Sam Bankman-Fried, FTX’s founder, would still be free. Instead, this former crypto billionaire is serving a 25 year prison sentence for his role in the 2022 collapse of FTX. **Further, questions of motive and intent will come up anytime we see headlines like the following:** ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/48ede503-ff96-45cd-ab40-0a595f7ab81b_776x243.png) ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/97949188-36a5-4f12-a10d-8a852b4d0319_811x731.png) There may be legitimate reasons for pausing or ending any investigation. But now some of them come with questions that would not have likely arisen had the SEC remained a fully independent agency. ### The shifts in sentiment among market players I discussed earlier are worth noting. Suggestions - even hints - that pardons and reduced enforcement efforts are the result of campaign contributions or other financial gain for those in charge are troubling. To the extent they continue, and depending how egregious they become, investors will start to lose confidence in capital markets, which could potentially impact your wealth. We're facing unprecedented challenges in U.S. capital markets. Let’s be careful out there. *\- John* **John P. Gavin, CFA, NACD.DC** [Subscribe](#/portal/signup) ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/70b0147f-e1eb-48fc-942c-41180b919da4_69x69-3.png) ### DI's Early Signals Report: March 28, 2025 URL: https://www.disclosureinsight.com/dis-early-signals-report-march-28/ Last updated: 2026-03-17T13:49:20.000Z ***Click on the PDF here to access a printable version of this report.*** [DI's Early Signals Report: March 28, 2025DI's Early Signals Report: March 28, 2025302 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/d642d2d4-b9fe-4e11-8771-87828c72dfe3.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What’s an Early Signal? DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation “confirmed” after we file an administrative appeal and have received a response that says as much. **Important:** The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security. In its responses, the SEC did not disclose the details on investigative activity referenced herein. All we know is that they somehow pertain to the conduct, transactions, and/or disclosures of the companies. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. 2. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 3. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 4. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. **All-access clients are welcome to contact us anytime to learn more.** [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### SEC Investigation Updates - March 27, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-march-27/ Last updated: 2026-03-17T13:49:21.000Z [Subscribe now](https://www.disclosureinsight.com/subscribe) ## Today’s report - - **Bristol-Myers Squibb Co. - BMY** - **Hormel Foods Corp. - HRL** - **Roku Inc. - ROKU** ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - March 27, 2025SEC Investigation Updates - March 27, 2025298 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/67ea4b81-4b8c-4831-9e19-1b975bdbc220.pdf "Download") [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### SEC Investigation Updates - March 24, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-march-24/ Last updated: 2026-03-17T13:49:21.000Z ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - NF - March 24, 2025SEC Investigation Updates - NF - March 24, 2025297 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/faa00397-9b7a-4f25-a452-0cb6101cf6d4.pdf "Download") [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### SEC Investigation Updates - March 19, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-march-19/ Last updated: 2026-03-17T13:49:21.000Z [Subscribe now](https://www.disclosureinsight.com/subscribe) ## Today’s report - ##### **American Water Works Company, Inc. (AWK)** ##### **Hewlett Packard Enterprise Co. (HPE)** ##### **Liveperson, Inc. (LPSN)** ##### **MicroStrategy Incorporated (MSTR)** ##### **Prospect Capital Corp. (PSEC)** ##### **Tesla Inc. (TSLA)** ***You need to click on the printable PDF here to access this report.*** [SEC Investigation Updates - March 19, 2025SEC Investigation Updates - March 19, 2025347 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/a6a07ffe-c4b1-466f-ac44-ab00fcc0ce53.pdf "Download") [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### Internal Controls Shortfalls Persist at AZEK Company URL: https://www.disclosureinsight.com/internal-controls-shortfalls-persist/ Last updated: 2026-03-17T13:49:21.000Z *A printable PDF version of this report appears at the bottom.* **Facts of Interest of Concern:** In May 2024, AZEK first announced accounting and internal controls problems that caused income before taxes to be overstated back to 2021\. We note the actual restatement says it’s, “for the years ended September 30, 2023, 2022 and 2021 *as well as prior periods*.” Those prior periods are not identified. \[Emphasis added\] The CFO left on short notice, in Jan-2025\. He had been in the role since Aug-2021\. Per the 10-Q filed in Feb-2025, internal controls were still not effective, as of 31-Dec-2024. In our work, an early signal of a possible SEC investigation was received on 21-Oct-2024\. Signal was then confirmed as an ongoing investigation on 06-Jan-2025\. This is a change from a response dated 12-Jan-2024, at which time no signs of ongoing SEC investigative activity were found. A search of SEC filings, back to the 10-K filed on 29-Nov-2022, found no clear disclosure of SEC investigative activity. We have no documents or meta-data from closed SEC probe(s) of this company. This is the first sign of an SEC investigation we found since we started covering AZEK in Mar-2023. [Subscribe now](https://www.disclosureinsight.com/subscribe) **Notable Items:** - 8-K filed 08-May-2024: Non-Reliance / Accounting issues first disclosed. From the earnings release, same day – > In the process of closing our fiscal quarter, we identified a discrepancy in an inventory balance. After a thorough investigation, it was determined that **a recently departed** \[*but never identified*\] **employee had inaccurately recorded inventory by creating unsupported manual journal entries that ultimately increased the value of inventory and decreased cost of sales.** The investigation has been substantially completed, and we have identified the adjustment ranges \[*that was quick*\]. These historical adjustments have no impact on net sales or the fundamental strength of our business model or operations. Our growth and productivity initiatives are on-track, and we are confident in our raised outlook. **Our core value is to ‘always do the right thing,’** and I am very proud of the team for identifying and immediately addressing this issue,” stated Mr. Singh. \[*Emphasis added*\] - NT 10-Q filed 08-May-2024 - 8-K filed 17-May-2024: NYSE Delisting Notice - 10-K/A filed 14-Jun-2024: Restates fiscal years ended Sep-2023, 2022, and 2021\. Material weaknesses in internal controls for same periods. 10-Q/A same day. - 10-Q filed 14-Jun-2024 : On 14-Jun-2024, AZEK regained compliance with the NYSE listing standards. Disclosure controls and procedures not effective as of March 31, 2024. - 10-Q filed on 08-Aug-2024: Disclosure controls and procedures not effective as of June 30, 2024 - 10-K filed on 20-Nov-2024: Disclosure controls and procedures not effective as of September 30, 2024 - 8-K filed on 06-Jan-2025: CFO left on short notice. On 06-Jan-2025, AZK announced the CFO was resigning, effective 24-Jan-2025, to pursue another opportunity with a private company. The CFO notified AZEK of his intention to resign on 30-Dec-2024. - 10-Q filed on 05-Feb-2025: Disclosure controls and procedures not effective as of December 31, 2024 **DI’s Take**: Our work suggests AZEK has known about an SEC investigation since at least Oct-2024\. Most troubling is the company is now well over three years with material weaknesses in internal controls. Recall, this dates back to at least the fiscal year-end Sep-2021\. Not good. We now point to CEO Jesse Singh’s remarks, back in May-2024, when the non-reliance was first announced. He said AZEK’s, “core value is to, ‘always do the right thing.’” Uh-huh. Apparently, doing the right thing does not include telling investors there’s now an SEC investigation to go along with protracted internal controls shortfalls. ***– John P. Gavin, CFA, NACD.DC*** [DI Report: Internal Controls Shortfalls Persist at AZEK CompanyDI Report: Internal Controls Shortfalls Persist at AZEK Company304 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/e3bacb01-bd8d-42dc-a70b-3123afeabbb1.pdf "Download") [Subscribe](#/portal/signup) **To learn more about our research process, including how to best use this information in your own decision-making,** [**click here**](https://probesreporter.com/our-research-process?ref=disclosureinsight.com)**.** **Our Terms of Service, relevant disclosures, and other legal notices** [**can be found here**](https://probesreporter.com/legal?ref=disclosureinsight.com)**.** ### DI's Early Signals Report: March 12, 2025 URL: https://www.disclosureinsight.com/dis-early-signals-report-march-12/ Last updated: 2026-03-17T13:49:22.000Z [DI's Early Signals Report: March 12, 2025DI's Early Signals Report: March 12, 2025303 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/c0de0999-1952-49ca-b2b6-3183d98cbce4.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What’s an Early Signal? DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation “confirmed” after we file an administrative appeal and have received a response that says as much. **Important:** The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security. In its responses, the SEC did not disclose the details on investigative activity referenced herein. All we know is that they somehow pertain to the conduct, transactions, and/or disclosures of the companies. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. 2. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 3. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 4. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. **All-access clients are welcome to contact us anytime to learn more.** [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### With Its Independence Removed, the SEC is Now Being Rapidly Dismantled. URL: https://www.disclosureinsight.com/with-its-independence-removed-the/ Last updated: 2026-03-17T13:49:23.000Z ### From John’s Desk … > "The SEC's independence is essential to its ability to effectively regulate the securities markets and protect investors … without fear of political interference or reprisal." Source: *Jay Clayton*, SEC chair, Trump’s first term Remarks at the Economic Club of New York September 09, 2019 ### US Capital Markets in Uncharted Regulatory Waters Now So much has happened at the SEC, in such a short period of time, that few market participants are even aware of the many changes impacting the agency now. This all since Donald Trump came back into the White House. Some of what we alert you to here could be overturned by the courts, but that is not a certainty. What is certain is this: The SEC’s ability to function will be greatly diminished, introducing risk and uncertainty to capital markets that will last for years to come. No matter your personal politics, if you participate in US capital markets, in any way, you will be impacted by this. We brief you here. **The SEC will no longer operate like it did before Inauguration Day 2025.** **It can’t.** **Too much has changed since then.** To be clear, what is taking place at the SEC right now is ***not*** like those changes that typically occur with each new change in administration. Different president, different priorities. We get it. No, what’s taken place at the SEC in recent weeks is of an unprecedented scale that most capital market participants will find unsettling. From its inception in the 1930s, and as clearly expressed in the related legislation, Congress designed the SEC as a bipartisan, expert, and independent agency. That’s gone now. Donor influence and political meddling have entered the chat. The changes we list for you below go much further than the SEC now reporting up to the White House. The related executive order that took away its independence was quickly followed by a series of debilitating cuts in personnel and facilities. Picture this: If the SEC were an automobile, you’d have a car that still looks the same but sputters and barely drives because so many of its systems and parts got removed. [Subscribe now](https://www.disclosureinsight.com/subscribe) ### Securities Laws Have Not Changed: There Will Now Be Less Staff and Resources to Enforce Them. **They’re Not Telling You This Part** **The rules haven’t changed.** Public companies still need to make their filings on time; initial public offerings (IPOs) still need to be reviewed; investment firms still need to be examined; novel investment products will still emerge; and, financial turmoil will surely occur again. The legislatively required oversight and establishment of boundaries that come with all of the above will now be done with reduced staff and resources. Something’s gotta give. ### Just Since Inauguration Day … As we said above, what the new president has done with the SEC is unprecedented - and will hurt its capacity to regulate markets for years. Let’s go through it chronologically. In early February, **the Trump administration made it harder for the SEC to open formal investigations.** This is expected to impede enforcement of securities laws. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/34bd2bb7-afc9-475f-8aa3-ce79986f2892_833x337.png) In mid-February **an Executive Order took away the SEC's independence.** ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/4535ec5c-0ef5-479e-8a43-9468e25df4d0_642x276.webp) On February, 18, 2025, by executive order, the SEC’s capacity to function as an independent agency was removed. Poof! Gone. Just like that. **Now, for the first time since it was established, the SEC will be overseen by unidentified staff at the White House** Office of Management and Budget (OMB), who have qualifications and expertise unknown. **With the ink barely dry on the order, Elon Musk’s DOGE crew of 20-somethings was inside the SEC.** The agency’s remaining capacities were then meaningfully reduced and/or compromised. This continues as we go to print. Here’s what we could glean from public sources - ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/3756d1e7-8263-4afd-a53d-8846d594df9a_755x237.webp) **Regional directors across 10 SEC field offices to be fired.** This removes the executive leadership of an entire level of the SEC’s organization chart. More importantly, in one fell swoop the SEC stands to lose untold decades of knowledge, expertise, and institutional memory. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/667bef5f-79c6-4c5e-9f55-ca9d110862c3_700x496.webp) **SEC field offices in Philadelphia and Los Angeles to close.** They wanted to close the Chicago office as well, but that effort failed, hitting contract termination problems. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/e57c3fd4-c39d-4fe0-98da-9ff8ada507eb_879x180.webp) **$50,000 buyout offers have been made to all eligible SEC employees** encouraging them to resign by April. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/49827668-2a0c-4f37-b663-d2cfec3985d0_748x194.png) Interesting side note: SEC employees are getting a better offer than those working for the Department of Health and Human Services. News reports as we go to print tell us HHS is only offering a $25,000 buyout to most of its workers. ### The United States has the strongest capital markets in the world. That’s now at risk. While not perfect, investors trust US capital markets. Until now the US regulatory environment for investors and registrants was robust, predictable, and generally free from political interference. This helped maintain the confidence of investors which, in turn, lowers the cost of raising capital here. Few realize the positive impact an independent SEC had on maintaining this system. Losing that won’t be free. **If there’s anything markets hate, it’s uncertainty.** Well, markets are being served up boatloads of uncertainty now. US capital markets have never experienced the systemic risk that comes with suddenly removing the independence of, and then weakening its primary regulator, especially over a period of just a few weeks. Worse, there are related risks that will show up unexpectedly, making them hard to assess, hedge, or discount. **Pay attention.** Get yourself current on the changes taking place at the SEC. Even within a disrupted regulatory regime, there will still be plenty of opportunities to make money. You may need to adjust your thinking to find them. While you’re at it, you probably should give higher mind share to avoiding losses than you might have in the past. **Remember: Serious investors don’t make excuses.** Serious investors figure out how to make money and avoid losses in any market or political environment. My commitment to help you do that has not changed. I’ll keep you updated. *\- John* John P. Gavin, CFA, NACD.DC direports@disclosureinsight.com [Subscribe](#/portal/signup) ### DI's Early Signals Report: March 06, 2025 URL: https://www.disclosureinsight.com/dis-early-signals-report-march-06/ Last updated: 2026-03-17T13:49:23.000Z [DI's Early Signals Report: March 06, 2025DI's Early Signals Report: March 06, 2025297 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/193f9c44-0757-48e3-b9bf-d33eb4a2dbe8.pdf "Download") [Subscribe now](https://www.disclosureinsight.com/subscribe) ### What’s an Early Signal? DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation “confirmed” after we file an administrative appeal and have received a response that says as much. **Important:** The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security. In its responses, the SEC did not disclose the details on investigative activity referenced herein. All we know is that they somehow pertain to the conduct, transactions, and/or disclosures of the companies. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. 2. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 3. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 4. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. All-access clients are welcome to contact us anytime to learn more. [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### From John’s Desk: March 03, 2025 URL: https://www.disclosureinsight.com/from-johns-desk-march-03-2025-2/ Last updated: 2026-07-03T18:02:11.000Z ### ***From John’s Desk*** *Disclosure Insight is now on Substack! With this transition, I’m introducing a new report format I wish had created a long time ago. It’s called, “From John’s Desk.”* *As I sift through countless company filings, I encounter numerous intriguing data points and observations. This report will highlight those findings, along with other random thoughts you may find interesting.* *As a reminder, for a limited time, all Disclosure Insight research content is free for subscribers. All Disclosure Insight reports published since January 2025, and some of our older reports, are already available on this platform for free.* *Please share this with others. I welcome your feedback and suggestions.* \- John [Subscribe now](https://www.disclosureinsight.com/subscribe) ### **DI Watch List - March, 2025** As occurs at the beginning of each month, tomorrow I’ll be sending out the March update to the DI Watch List of companies with confirmed, undisclosed SEC investigations. This is our most popular report. There’s now 104 companies that have been hiding their SEC investigations from you. 12 new ones were added in the past month. 104 companies is significantly higher than the number of undisclosed SEC investigations we’ve been following in recent years; typically about 75-85\. I’m still assessing the implications of this spike and will update you as I learn more. ### On Deck **Reports:** We have a lot of Early Signals® of possible SEC investigations in the house to get out. Expect them this week. After that, expect another round of of SEC Investigation Update Reports. Probably early next week. **Trump Stuff:** Like many, you may find it challenging to keep up with the developments emerging from this new White House. The implications for the SEC may not be on your radar, but they should be. I’ll have a separate note to brief you on that as well. Today’s “*From John’s Desk*” was to let you know we’re live here on Substack and what’s coming this week. That’s all for now. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/07/70b0147f-e1eb-48fc-942c-41180b919da4_69x69-4.png) ### SEC Investigation Updates - February 12, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-february/ Last updated: 2026-03-17T13:49:23.000Z [SEC Investigation Updates - NF - February 12, 2025SEC Investigation Updates - NF - February 12, 2025299 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/6a17617d-1eed-4505-90b2-95379a2efb72.pdf "Download") [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### SEC Investigation Updates - February 11, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-february-2c9/ Last updated: 2026-03-17T13:49:24.000Z [SEC Investigation Updates - February 11, 2025SEC Investigation Updates - February 11, 2025391 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/b5ca9063-63f0-44ed-b7ac-5e0092cbcc4b.pdf "Download") [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### DI's Early Signals Report: February 06, 2025 URL: https://www.disclosureinsight.com/dis-early-signals-report-february-b69/ Last updated: 2026-03-17T13:49:24.000Z [DI's Early Signals Report: February 06, 2025DI's Early Signals Report: February 06, 2025298 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/b5d358a9-2a76-49ba-8e5b-550599b6b326.pdf "Download") [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### DI's Early Signals Report: February 05, 2025 URL: https://www.disclosureinsight.com/dis-early-signals-report-february/ Last updated: 2026-03-17T13:49:24.000Z [DI's Early Signals Report: February 05, 2025DI's Early Signals Report: February 05, 2025297 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/b0e8662c-0d7b-43aa-8d4b-f7779fb3bef3.pdf "Download") [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### SEC Investigation Updates - January 28, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-january-6f9/ Last updated: 2026-03-17T13:49:24.000Z [SEC Investigation Updates - January 28, 2025SEC Investigation Updates - January 28, 2025406 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/e05e4992-6b91-4e28-bda9-bd5a0254d2ea.pdf "Download") [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### SEC Investigation Updates - January 23, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-january-d68/ Last updated: 2026-03-17T13:49:25.000Z [SEC Investigation Updates - January 23, 2025SEC Investigation Updates - January 23, 2025427 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/009fbec1-6123-4902-8762-3890f729216d.pdf "Download") [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### SEC Investigation Updates - January 22, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-january-742-2/ Last updated: 2026-07-03T18:02:14.000Z [SEC Investigation Updates - NF - January 22, 2025SEC Investigation Updates - NF - January 22, 2025314 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/84aa9372-c744-4136-a023-7dda7dd73bb9.pdf "Download") [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### SEC Investigation Updates - January 22, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-january-742-3/ Last updated: 2026-07-23T23:26:35.000Z [SEC Investigation Updates - NF - January 22, 2025SEC Investigation Updates - NF - January 22, 2025314 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/84aa9372-c744-4136-a023-7dda7dd73bb9.pdf "Download") [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### DI's Early Signals Report: January 21, 2025 URL: https://www.disclosureinsight.com/dis-early-signals-report-january/ Last updated: 2026-03-17T13:49:25.000Z [DI's Early Signals Report: January 21, 2025DI's Early Signals Report: January 21, 2025301 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/a4af6912-cb52-4139-994a-a9c4abc9a283.pdf "Download") [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### SEC Investigation Updates - January 15, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-january-5cf/ Last updated: 2026-03-17T13:49:25.000Z [SEC Investigation Updates - January 15, 2025SEC Investigation Updates - January 15, 2025365 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/de1f3cd3-c326-4c87-b94f-b5dcef62c023.pdf "Download") [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### SEC Investigation Updates - January 07, 2025 URL: https://www.disclosureinsight.com/sec-investigation-updates-january/ Last updated: 2026-03-17T13:49:26.000Z [SEC Investigation Updates - NF - January 07, 2025SEC Investigation Updates - NF - January 07, 2025297 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/847ba8e5-8b95-4b06-96a0-85883e3477f3.pdf "Download") [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### DI's Early Signals Report: January 06, 2025 URL: https://www.disclosureinsight.com/test-dis-early-signals-report-january/ Last updated: 2026-03-17T13:49:26.000Z [Di Early Signals Report: January 06, 2025Di Early Signals Report: January 06, 2025303 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/38364441-0174-457f-a029-90a8d84f2960.pdf "Download") [Subscribe](#/portal/signup) Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### DI Report: Boston Scientific’s FCPA Problems Go Beyond Vietnam … Again URL: https://www.disclosureinsight.com/di-report-boston-scientifics-fcpa/ Last updated: 2026-03-17T13:49:27.000Z **Summary and Opinion:** Are we back in China? Boston Scientific had a relatively recent Foreign Corrupt Practices Act (FCPA) investigation involving China it never disclosed. It ended just two years before a disclosed one involving Vietnam started. In Aug-2024, the company said its Vietnam FCPA investigation has expanded. Not good. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/862fb36d-7a3a-4f72-9d58-082418a6b82b_921x328-1.png) [DI Report: Boston Scientific’s FCPA Problems Go Beyond Vietnam … AgainDI Report: Boston Scientific’s FCPA Problems Go Beyond Vietnam … Again610 KBdownload-circle](https://direports.substack.com/api/v1/file/30aad937-ccd2-481a-8f83-9326f4c5a3d5.pdf "Download") - In Aug-2022, Boston Scientific first disclosed that in Mar-2022, "it received a whistleblower letter alleging Foreign Corrupt Practices Act violations in Vietnam.” - **We doubt many investors caught this.** In its most recent 10-Q, filed in Aug-2024, the company tells us **the Vietnam FCPA investigation has expanded.** It now involves “foreign regulators,” “other potential concerns in Vietnam,” and, “other countries,” none of which have been identified. - **This is new information, from our research.** Boston Scientific had **a recent and separate FCPA investigation involving China it never disclosed.** It ended in Feb-2020, just two years before the new one in Vietnam started in Mar-2022\. We have a document showing the China FCPA investigation was expansive, with a five-year look back to 2013\. (Excerpts below.) **Think about it**: The Vietnam FCPA exposure was disclosed, and relatively quickly too. But a seemingly larger FCPA investigation just two years earlier involving China was not? It doesn’t add up. **Now, consider this:** When the Vietnam matter was first disclosed in Aug-2022, Boston Scientific assured investors it was, “cooperating with government agencies while investigating these allegations.” **Now, fully two years after that first disclosure, the company still hasn’t said a peep about the results of its internal investigation.** Why? When they can, companies are quick to tell you when their internal investigations find no wrongdoing. But when they find problems, many stay silent, recognizing few investors will think to follow-up. That appears to be the case here. **DI’s Take: Why the Vietnam FCPA Exposure is Bad** Boston Scientific’s management and board previously concluded they could keep you in the dark on an expansive FCPA investigation involving China. Yet they judged a more recent Vietnam FCPA exposure had to be disclosed? That reveals their view on the Vietnam matter. Further, that earlier FCPA investigation involving China created an investigative record for Boston Scientific. Regulators have long institutional memories on these things. With jaded eye, earlier promises made to go forth and sin no more will now be resurrected and challenged. The fact Boston Scientific’s Vietnam FCPA investigation has now expanded begs these important questions: - Where / How has it expanded? - Why are you telling us now? - Are investigators focusing on China again? - If not, why are you not identifying the countries and regulators involved in the expanded investigation? The absence of detail on these items leaves you unable to adequately assess the added risk to Boston Scientific now. Finally, we note that FCPA matters are often blown-off by investors. That’s a mistake. **Ask yourself: What’s the proper accounting treatment for a bribe?** - At their core, FCPA investigations are about deficiencies in accounting and internal controls. - Further, as an SEC investigation proceeds, the pressure can build to rein-in practices previously used to conduct business. This can make it harder to hit revenue and profit targets that were previously met. ***– John P. Gavin, CFA*** *Investigation timeline with document excerpts below.* **Timeline of Boston Scientific’s Vietnam FCPA Investigation** **Mar-2022**: Boston Scientific received a whistleblower letter alleging Foreign Corrupt Practices Act violations in Vietnam. It was not disclosed for five more months. **From the Boston Scientific 10-Q filed on 04-Aug-2022:** **First disclosure of Vietnam whistleblower letter.** > In March 2022, the Company received a whistleblower letter alleging Foreign Corrupt Practices Act violations in Vietnam. The Company is cooperating with government agencies while investigating these allegations. **DI’s Take**: For five months, Boston Scientific did not think the whistleblower allegations were serious enough to disclose. Something changed to alter their thinking on that. Further, since this first disclosure, at no time has Boston Scientific spoken to the results of its own investigation into the Vietnam whistleblower’s allegations. We note the earnings call held 27-Jul-2022 was silent on the Vietnam exposure. **Oct-2022:** Boston Scientific received a DOJ subpoena related to the FCPA allegation. **From the Boston Scientific 10-Q filed on 03-Nov-2022:** **First disclosure of receipt of an Oct-2022 DOJ subpoena.** > In March 2022, the Company received a whistleblower letter alleging Foreign Corrupt Practices Act violations in Vietnam. In October 2022, ***the Company received a subpoena for documents from the Office of the U.S. Attorney*** for the District of Massachusetts. The Company is cooperating with government agencies while investigating these allegations. **DI’s Take**: As you can plainly see, in that 10-Q, only the US Attorney’s involvement was disclosed, but not the SEC. That’s unusual, as FCPA investigations are typically conducted by both the SEC and DOJ at the same time. The earnings call held 26-Oct-2022 was silent on the Vietnam exposure and the related US Attorney subpoena. **From the Boston Scientific 10-K filed on 23-Feb-2023:** **First disclosure of an SEC subpoena.** > In March 2022, the Company received a whistleblower letter alleging Foreign Corrupt Practices Act violations in Vietnam. The Company has received related ***subpoenas for documents*** from the Office of the U.S. Attorney for the District of Massachusetts and ***the Securities and Exchange Commission***. The Company is cooperating with government agencies while investigating these allegations. **DI’s Take**: We note the earnings call held 01-Feb-2023 was again silent on the Vietnam exposure and the related US Attorney and SEC subpoenas. The above disclosure was then repeated in every quarterly filing since that 10-K in Feb-2023, with no update or further detail. That is, until the 10-Q filed on 01-Aug-2024\. The Aug-2024 10-Q is the first time we learn Boston Scientific’s Vietnam FCPA investigation has now expanded in three troubling ways. As highlighted below, it now involves “foreign regulators,” “other potential concerns in Vietnam,” and, “other countries,” none of which have been identified. **From the Boston Scientific 10-Q filed on 01-Aug-2024:** > Like many healthcare companies, the Company receives inquiries and has ongoing discussions with governmental agencies with respect to the Company’s operations, such as the Securities and Exchange Commission (SEC), the Department of Justice (DOJ) ***and foreign regulators***, including its operations in Vietnam with respect to alleged Foreign Corrupt Practices Act (FCPA) violations the Company received in March 2022\. The Company has received related subpoenas for documents from the DOJ and the SEC with respect to the Vietnam matter, and is cooperating with the government while investigating these allegations. From time to time, the Company also self-discloses potential concerns to regulators. In the course of Vietnam-related discussions with the DOJ and SEC, the Company has disclosed that it is investigating ***other potential concerns in Vietnam*** and ***other countries***. **Excerpt from SEC document request Sent to Boston Scientific on April 03, 2018** ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/e512f702-3f87-4ceb-96c2-a67616743414_678x518.png) **Excerpt from SEC document request Sent to Boston Scientific on April 03, 2018** ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/a8aec8c3-1633-4389-bc90-95663ca5d9ec_678x683.png) **SEC Investigation Termination Letter Sent to Boston Scientific on February 25, 2020** ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/c96b2d9b-d73b-4a02-afe4-43d4c5d77988_678x701.png) **To learn more about our research process, including how to best use this information in your own decision-making,** [**click here**](https://probesreporter.com/our-research-process?ref=disclosureinsight.com)**.** **Our Terms of Service, relevant disclosures, and other legal notices** [**can be found here**](https://probesreporter.com/legal?ref=disclosureinsight.com)**.** ### SEC Investigation Updates - September 16, 2024 URL: https://www.disclosureinsight.com/sec-investigation-updates-september/ Last updated: 2026-03-17T13:49:27.000Z [Subscribe](#/portal/signup) [SEC Investigation Updates - September 16, 2024SEC Investigation Updates - September 16, 2024474 KBdownload-circle](https://direports.substack.com/api/v1/file/a3f0dbec-f191-4520-8ec1-deaa1c717bbb.pdf "Download") Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### DI Early Signals Report - September 10, 2024 URL: https://www.disclosureinsight.com/di-early-signals-report-september/ Last updated: 2026-03-17T13:49:27.000Z *Early Signals™ in this report are only POSSIBLE indicators of SEC investigative activity.* *They are instances wherein the SEC cited the "law enforcement exemption" of the Freedom of Information Act (FOIA) as basis to block our access to records we sought on the public companies included in this update.* *As a matter of law, the SEC is acknowledging some sort of investigative activity with this response. We call this an early signal of an SEC investigation. However, these signals have not yet been confirmed through the administrative appeal process.* ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/e46cb3a9-8b1a-48cc-b28f-8fe74d73a085_568x186.png) [DI Early Signals Report - September 10, 2024DI Early Signals Report - September 10, 2024334 KBdownload-circle](https://direports.substack.com/api/v1/file/242eddab-5089-40ae-9217-a58c72fe5dc3.pdf "Download") ### **What’s an Early Signal?** **DI’s EARLY SIGNALS are only POSSIBLE indicators of SEC investigative activity**. We are publishing these data to give you the earliest indication of the existence of a possible SEC investigation. That is why we use the term “possible” in describing SEC investigations at this point in our research process. We will only describe an investigation “confirmed” after we file an administrative appeal and have received a response that says as much. **Important**: **The SEC reminds us that its assertion of the law enforcement exemption should not be construed as an indication by the Commission or its staff that any violations of law have occurred with respect to any person, entity, or security**. In its responses, the SEC did not disclose the details on investigative activity referenced herein. All we know is that they somehow pertain to the conduct, transactions, and/or disclosures of the companies. **The data we present here is recently received.** New SEC investigative activity could theoretically begin or end after the date covered by the latest information in this report, which would not be reflected here. Unless we indicate otherwise, we will continue the research process on these companies and may publish updates at any time. The FOIA data reflected in this report are only current as of the dates indicated for each individual company. Similarly, public company activities and/or disclosures made since the dates indicated herein could impact your analysis. **Only companies with confirmed, undisclosed SEC investigations are maintained on our Watch List of companies with undisclosed SEC investigations.** If SEC investigative activity has already been disclosed by a company as we go to print, we will endeavor to tell you as much. Further, we may have researched and published on some of these companies in the past. It’s also possible some of the companies are already on our Watch List of companies with Confirmed, Undisclosed SEC Investigations. An update to our Watch List report is published at the beginning of each month. **There are several reasons the SEC might cite the law enforcement exemption as basis to block our access to records.** Not all would be of concern to investors today. After we receive an Early Signal of a possible SEC investigation, we then file an administrative appeal with the Office of the General Counsel of the SEC on the company in question. After careful review of our appeal, the General Counsel’s office typically informs us of one of the following: 1\. An ongoing enforcement proceeding is confirmed. Only then will we use the term “confirmed” next to the company’s name on our Watch List. 2\. There was an investigation that is now over and the file has been remanded for further processing. We may learn more about what took place if the SEC provides documents to us. 3\. There are no records responsive to our request. This could be because there was an investigation that concluded in the past but the SEC’s records were not current at the time of our request. Alternatively, there may be an investigation involving not the company, but some other person or entity and the company was incidentally named or tangentially listed. 4\. Rarely, the appeal response will inform us a clerical error was made by the SEC’s FOIA Office in processing our original request. Clients are welcome to contact us anytime to learn more. *Disclosure Insight research provides data, commentary, and analysis on public company interactions with investors and with the SEC. Our work is heavily reliant on company disclosures and our expertise in using the Freedom of Information Act.* **To learn more about our research process, including how to best use this information in your own decision-making,** [**click here**](https://probesreporter.com/our-research-process?ref=disclosureinsight.com)**.** **Our Terms of Service, relevant disclosures, and other legal notices** [**can be found here**](https://probesreporter.com/legal?ref=disclosureinsight.com)**.** **Copyright Warning and Notice** The works of authorship contained in the accompanying material, including but not limited to all data, design, text, images, charts and other data compilations or collective works are owned by Disclosure Insight, Inc. or one of its affiliates and may not be copied, reproduced, transmitted, displayed, performed, distributed, rented, sublicensed, altered, or stored for subsequent use, in whole or in part in any manner, without the prior written consent of Disclosure Insight, Inc. Photocopying or electronic distribution of any of the accompanying material or contents without the prior written consent of Disclosure Insight, Inc. violates U.S. copyright law, and may be punishable by statutory damages of up to $150,000 per infringement, plus attorneys’ fees (17 USC 504 et. seq.). Without advance permission, illegal copying includes regular photocopying, faxing, excerpting, forwarding electronically, and sharing of online access. **Intellectual Property** © 2016-2024, Disclosure Insight, Inc. All rights reserved. Disclosure Insight®; Probes Reporter®; They Know it. Now You Know It.®; Better Disclosure for Better Decisions®; Assess the Risk. Achieve the Return™; DI™; Early Signals™;and, Disclosure Games®, are trademarks of Probes Reporter, LLC and are proprietary. ### DI Report: Abbott Labs Hurts its Credibility by Masking an SEC Investigation URL: https://www.disclosureinsight.com/di-report-abbott-labs-hurts-its-credibility/ Last updated: 2026-03-17T13:49:28.000Z *“Disclosure Games” is a term we use to highlight those public companies engaging in disclosure practices we find as misleading, confusing, evasive, or otherwise lacking the transparency needed for investors to make well-informed investment decisions regarding a potentially material exposure.* In this note, we argue Abbott is playing Disclosure Games by the selective omission of key words investors typically screen for when looking to see if a company has regulatory or legal exposure. By doing so, Abbott now risks investors viewing it as a company willfully trying to deceive them. In our opinion, that perception is well placed. [DI Report: Abbott Labs Hurts its Credibility by Masking an SEC InvestigationDI Report: Abbott Labs Hurts its Credibility by Masking an SEC Investigation272 KBdownload-circle](https://direports.substack.com/api/v1/file/eb354c29-6fe5-4697-9055-5c8fc87bc70c.pdf "Download") Before we share the offending disclosure language, let’s quickly review the history that brought Abbott – and us, to this moment. After several infants fell ill in early 2022, regulators found unsanitary conditions at an Abbott factory in Sturgis, Michigan. At the peak of the crisis, Abbott was regularly in the news over the matter and, eventually, voluntarily recalled its powdered formula and shut the plant. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/283d33c0-4a92-43b1-bcfe-f8c98496e341_681x382-1.png) **The DI Research History:** We found the SEC has been investigating Abbott since at least Jun-2023, with ongoing enforcement proceedings now confirmed two times since, most recently as of 05-Aug-2024\. Abbott is on the DI Watch List of companies with confirmed, undisclosed SEC investigations, as a search of the company’s SEC filings, back to Jul-2021, found no clear disclosure of SEC investigative activity. ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/da0ddf39-0e66-41a8-a452-5bc1d4bcee70_67x67.png) **Notable Item:** In the 10-K filed on 17-Feb-2023, and again without update in the 10-K filed 16-Feb-2024, we see this, > In December 2022, **Abbott received a subpoena from the Enforcement Division of the Commission** requesting information relating to Abbott’s powder infant formula business and related public disclosures. **DI's Take**: We’ve never once seen a public company describe an SEC subpoena as Abbott does in its filings. Despite the ~~sleazy~~ clever word-smithing regarding a subpoena from, “the Commission” as cited above, at no time does Abbott make it clear it has a formal SEC investigation that likely started well before Dec-2022\. **Writing disclosures in this manner does more harm than good.** Worse, few professional investors would have been rattled to learn the SEC was one of the many regulators looking into Abbott’s baby formula problems at the time. Instead, they now see a company that’s demonstrated a willful – and twice repeated, intent to deceive them. So why do this? To get further insight, we suggest taking a look at this New York Times article, published in Sep-2022\. In it, the author describes Abbott’s scorched-earth tactics from long before the 2022 recall when it came to accusations its baby formula might not be safe. [**How Abbott Kept Sick Babies From Becoming a Scandal**](https://www.nytimes.com/2022/09/06/business/abbott-baby-formula-lawsuits-jones-day.html?ref=disclosureinsight.com) ![](https://storage.ghost.io/c/8d/91/8d9100ad-32c1-48e5-abdb-372ab199e141/content/images/2026/03/9db1fafa-ff76-4dcd-8ab6-66a30575dc3f_1224x685.png) For our part, we will keep it simple: When it comes to material exposures, investors require clarity, not ~~sleazy~~ clever word games. It’s well past time Abbott fixes this. ### SEC Investigation Updates - August 29, 2024 URL: https://www.disclosureinsight.com/sec-investigation-updates-august/ Last updated: 2026-03-17T13:49:28.000Z [Subscribe](#/portal/signup) [SEC Investigation Updates - August 29, 2024SEC Investigation Updates - August 29, 2024427 KBdownload-circle](https://direports.substack.com/api/v1/file/378c20ca-6222-413b-9444-83818a4e343e.pdf "Download") Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### SEC Investigation Updates - August 27, 2024 URL: https://www.disclosureinsight.com/sec-investigation-updates-august-b1c/ Last updated: 2026-03-17T13:49:29.000Z [Subscribe](#/portal/signup) As of the dates shown in the today’s report, we received Freedom of Information Act (FOIA) responses from the SEC to suggest the absence of recent SEC investigative activity. If you think any of these companies have SEC investigations, or had them in the recent past, let us know and we’ll look into it. Data presented are only current as of the Date of Response. [SEC Investigation Updates - August 27, 2024SEC Investigation Updates - August 27, 2024343 KBdownload-circle](https://direports.substack.com/api/v1/file/d1bbf93b-8702-43c7-ad9c-84da98002111.pdf "Download") Thanks for reading Disclosure Insight®! This post is public so feel free to share it. ### DI Report: UPS’s Disclosure of its SEC Investigation Doesn’t Add Up URL: https://www.disclosureinsight.com/di-report-upss-disclosure-of-its/ Last updated: 2024-06-17T15:55:00.000Z After nearly fours years of staying silent about it, in May UPS finally disclosed that SEC investigation we had been tracking since Nov-2019, and warned on repeatedly since. Per the 10-Q filed on a Friday, 03-May-2024, at 4:48 pm EDT, UPS said the SEC is investigating matters related to, and including a goodwill impairment charge recorded during the quarter ending 31-Dec-2020\. The company also says it is discussing a resolution with the SEC, but it does not sound like things are going so well. With this new disclosure, on 02-Jun-2024, we removed UPS from the DI Watch List of companies with confirmed, undisclosed SEC investigations. This is your follow-up. [UPS’s Disclosure of its SEC Investigation Doesn’t Add Up UPS’s Disclosure of its SEC Investigation Doesn’t Add Up 298 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/628356ef-abd7-4101-ad27-cf1130cbe4b1.pdf "Download")