SEC v. Candlestick Capital Management LP (rule 105 offering shorts, 2023)

Settled

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In February 2023 the Securities and Exchange Commission settled an administrative order with Candlestick Capital Management LP for a breach of Rule 105 of Regulation M, ordering it to cease and desist. The money from the same facts is recorded on the companion court record.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

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Alleged gain

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A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

What is alleged to have happened

The Securities and Exchange Commission announced this matter on February 21, 2023 as release 34-96952. The respondents named are Candlestick Capital Management LP (0 individuals, 1 entity).

The order finds the adviser bought in a public offering for fund clients after selling the same stock short in the Rule 105 restricted period and orders it to cease and desist. It imposes no money; the penalty, disgorgement and interest arising from the same facts are in the court judgments recorded in the companion litigation-release record.

This library tags the matter as rule 105 offering shorts, based on the conduct the regulator describes. Each tag links to a page explaining how that technique works, what statute it engages, and what penalties comparable actions have attracted. The tagging is ours, not the regulator's: agencies charge statutory provisions, not technique names.

The order itself imposes no money.

For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the release.

What technique is this, and how does it work?

This action is tagged with one technique in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.

• Rule 105 offering shorts — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2023-02-21 Administrative proceeding instituted (cease-and-desist)

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

• SEC order

The linked release is a work of the United States government and is not subject to copyright. Our summary and narrative above are our own writing.

Same matter

The library links these 2 records because they appear to concern one matter: the same lead defendant, an overlapping technique tag and close filing dates, or a shared court docket or a release that cites the other. Records are listed by date filed.

This grouping is the library's, made by matching names, techniques, dates and citations when the site is built. It is not the regulator's or a court's determination that the records are one case, and it errs towards missing a link rather than making a false one.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added September 20, 2026. submit a correction.