SEC v. Tod A. Ditommaso, Esq. (undisclosed control blocks, 2016)

Settled

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In September 2016 the SEC instituted proceedings against attorney Tod DiTommaso over opinion letters he wrote for Fusion Pharm shares. On December 21, 2018, on his offer of settlement, the Commission ordered disgorgement of $1,475 and a $1,475 penalty, which he had already paid.

The record

What was ordered

Civil penalty

$1.5k

Disgorgement

$1.5k

Prejudgment interest

—

Total relief

$3k

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, 2016 as release 33-10215. The respondents named are Tod A. Ditommaso, Esq. (1 individual, 0 entities).

This library tags the matter as undisclosed control blocks and unregistered distributions, 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 conduct is recorded against equities, with OTC identified in the release.

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.

The SEC's administrative file for proceeding 3-17550 shows that after the case was affected by the Supreme Court's Lucia decision and then stayed, the Commission issued an order on December 21, 2018 making findings and imposing sanctions, entered on DiTommaso's offer of settlement. It orders disgorgement of $1,475 and a civil penalty of $1,475, noting that he had already paid them under a June 13, 2017 initial decision issued after a May 2017 hearing; the case was remanded for a new judge after the Supreme Court's Lucia decision before the settlement. The findings are made on his offer of settlement and he did not admit them for other proceedings. Checked on 2026-10-04.

What technique is this, and how does it work?

This action is tagged with 2 techniques 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.

• Undisclosed control blocks — see how it works, what statute it engages, and every other action tagged the same way.
• Unregistered distributions — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2016-09-16 Administrative proceeding instituted (cease-and-desist)
2. 2018-12-21 Commission order imposing sanctions on DiTommaso's offer of settlement (33-10597)

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
• SEC order imposing remedial sanctions (Dec. 21, 2018)
• SEC administrative proceeding file 3-17550

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 3 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 10, 2026. submit a correction.