SEC v. Nob Hill Capital Management, Inc. (rule 105 offering shorts, 2014)

Settled

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In September 2014, the Securities and Exchange Commission settled an administrative order with Nob Hill Capital Management, Inc., finding Rule 105 breaches. The order requires disgorgement of $95,902 and prejudgment interest of $6,663.

The record

What was ordered

Civil penalty

—

Disgorgement

$95.9k

Prejudgment interest

$6.7k

Total relief

$103k

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 Securities and Exchange Commission announced this matter on September 16, 2014 as release 34-73108. The respondents named are Nob Hill Capital Management, Inc. (0 individuals, 1 entity).

The order finds that the respondent bought shares in public offerings after selling the same stock short during the Rule 105 restricted period and without an applicable exception. Rule 105 of Regulation M applies whatever the trader intended; the findings are made without admitting or denying them. The order directs payment of the disgorgement and interest but waives it on the respondent's sworn statement of financial condition, so nothing was imposed in practice; no penalty was imposed.

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 relief recorded in our data is disgorgement of $95,902 and prejudgment interest of $6,663. Penalty and disgorgement are distinct: disgorgement returns the gain, while the penalty is punitive. We store them separately so that aggregate figures across the library are not double-counted.

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. 2014-09-16 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.

Related actions

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

Record added September 20, 2026. submit a correction.