SEC v. Molina (insider trading, 2018)

Judgment entered

✓ Checked against the primary document on October 3, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, with sampled and disputed records read a second time. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.

Report an error in this record (sec-molina-insider-trading-2018) by email

In July 2018 the SEC settled with Nelson Molina, a former ClubCorp investor relations vice president who bought company stock after learning it was exploring a sale. He agreed to disgorge his gains and pay a $39,230 penalty, half the disgorgement amount, which implies disgorgement of $78,460.

The record

What was ordered

Civil penalty

$39.2k

Disgorgement

$78.5k

Prejudgment interest

—

Total relief

$118k

Alleged gain

—

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 SEC alleged that Molina, despite having signed ClubCorp's trading policies, bought company stock while aware that it was exploring significant transactions, and that the stock then rose more than 16 percent, adding over $78,000 to the value of his holding. After a FINRA inquiry he acknowledged the trading and resigned, and his lawyer reported it to the SEC. He agreed to a final judgment enjoining him under Section 10(b) and Rule 10b-5, disgorgement, and a penalty of $39,230. The disgorgement figure is derived from the release's statement that the penalty is half of it.

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.

• Insider trading — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2018-07-05 Litigation release published

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 litigation release

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.

Related actions

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

Record added September 10, 2026. submit a correction.