Home / Cases / Rule 105 offering shorts Rule 105 offering shorts enforcement actions This library records 84 enforcement actions tagged rule 105 offering shorts. Rule 105 offering shorts are short sales of a stock in the restricted period before a follow-on offering is priced, followed by a purchase of that stock in the offering, which Regulation M Rule 105 prohibits whatever the trader intended.
Actions are listed newest first. Each row links to a case page carrying the regulator's own release and, where one was published, the complaint. For how this technique works and what statute it engages, read the rule 105 offering shorts technique page.
Actions 84
Total penalties $20.5m
Median penalty $107k
Largest $2.5m
Criminal parallel 0% Action Agency Filed Penalty Status SEC v. Sourcerock Group, LLC (rule 105 offering shorts, 2025) SEC 2025-08-04 $250k settled SEC v. Snow Lake Capital (HK) Limited (rule 105 offering shorts, 2024) SEC 2024-12-19 $525k settled SEC v. FiveT Capital AG (rule 105 offering shorts, 2024) SEC 2024-11-26 $805k settled SEC v. Centerline Investment Management Limited (rule 105 offering shorts, 2024) SEC 2024-09-23 $112k settled SEC v. Gates Capital Management, Inc. (rule 105 offering shorts, 2024) SEC 2024-09-17 $57.6k settled SEC v. Kershner Trading Americas, LLC (rule 105 offering shorts, 2024) SEC 2024-05-20 $812k settled SEC v. Contrarian Capital Management, L.L.C. (rule 105 offering shorts, 2024) SEC 2024-02-21 $140k settled SEC v. Anson Advisors Inc. (rule 105 offering shorts, 2023) SEC 2023-10-19 $600k settled SEC v. Candlestick Capital Management LP (rule 105 offering shorts, 2023) SEC 2023-02-21 $810k settled SEC v. HITE Hedge Asset Management LLC (rule 105 offering shorts, 2023) SEC 2023-02-21 $104k settled SEC v. Candlestick Capital Management LP et al. (rule 105 offering shorts, 2023) SEC 2023-02-17 $810k settled SEC v. HITE Hedge Asset Management LLC et al. (rule 105 offering shorts, 2023) SEC 2023-02-17 $104k settled SEC v. Weiss Asset Management LP (rule 105 offering shorts, 2022) SEC 2022-06-14 $200k settled SEC v. Helikon Investments Ltd. (rule 105 offering shorts, 2021) SEC 2021-09-21 $97.5k settled SEC v. Andrew F. Nicoletta (rule 105 offering shorts, 2018) SEC 2018-12-19 $371k settled SEC v. Millennium Management LLC (rule 105 offering shorts, 2017) SEC 2017-10-31 $300k settled SEC v. Palestra Capital Management LLC (rule 105 offering shorts, 2017) SEC 2017-01-26 $80k settled SEC v. 2 West, Inc. (rule 105 offering shorts, 2016) SEC 2016-06-14 $707k settled SEC v. Auriga Global Investors Sociedad De Valores S.A. (rule 105 offering shorts, 2015) SEC 2015-10-14 $179k settled SEC v. Harvest Capital Strategies LLC (rule 105 offering shorts, 2015) SEC 2015-10-14 $65k settled SEC v. J.P. Morgan Investment Management Inc. (rule 105 offering shorts, 2015) SEC 2015-10-14 $365k settled SEC v. Omega Advisors, Inc. (rule 105 offering shorts, 2015) SEC 2015-10-14 $65k settled SEC v. Sabby Management, LLC (rule 105 offering shorts, 2015) SEC 2015-10-14 $91.7k settled SEC v. War Chest Capital Partners LLC (rule 105 offering shorts, 2015) SEC 2015-10-14 $150k settled SEC v. Charles Raymond Langston III, CRL Management, LLC, and Guarantee Reinsurance, Ltd. (insider trading, 2015) SEC 2015-06-11 $502k judgment SEC v. Keypoint Capital Management, LLC (rule 105 offering shorts, 2015) SEC 2015-03-19 $65k settled SEC v. Pennington Capital Management LLC and Robert J. Evans (rule 105 offering shorts, 2014) SEC 2014-11-12 $65k settled SEC v. Thrasos Tommy Petrou (rule 105 offering shorts, 2014) SEC 2014-10-27 — settled SEC v. Advent Capital Management, LLC (rule 105 offering shorts, 2014) SEC 2014-09-16 $65k settled SEC v. Antipodean Advisors LLC (rule 105 offering shorts, 2014) SEC 2014-09-16 $65k settled SEC v. Blackrock Institutional Trust Company, N.A. (rule 105 offering shorts, 2014) SEC 2014-09-16 $530k settled SEC v. East Side Holdings II, Inc. (rule 105 offering shorts, 2014) SEC 2014-09-16 $130k settled SEC v. Explorador Capital Management, LLC (rule 105 offering shorts, 2014) SEC 2014-09-16 $65k settled SEC v. Formula Growth, Ltd. (rule 105 offering shorts, 2014) SEC 2014-09-16 $65k settled SEC v. Great Point Partners, LLC (rule 105 offering shorts, 2014) SEC 2014-09-16 $65k settled SEC v. Indaba Capital Management, L.P. (rule 105 offering shorts, 2014) SEC 2014-09-16 $97.4k settled SEC v. Ironman Capital Management, LLC (rule 105 offering shorts, 2014) SEC 2014-09-16 $65k settled SEC v. James C. Parsons (rule 105 offering shorts, 2014) SEC 2014-09-16 $67.8k settled SEC v. Midwood Capital Management LLC (rule 105 offering shorts, 2014) SEC 2014-09-16 $65k settled SEC v. Nob Hill Capital Management, Inc. (rule 105 offering shorts, 2014) SEC 2014-09-16 — settled SEC v. RA Capital Management, LLC (rule 105 offering shorts, 2014) SEC 2014-09-16 $905k settled SEC v. Rockwood Investment Management, Inc. (rule 105 offering shorts, 2014) SEC 2014-09-16 $72.1k settled SEC v. Seawolf Capital, LLC (rule 105 offering shorts, 2014) SEC 2014-09-16 $96.4k settled SEC v. Solus Alternative Asset Management LP (rule 105 offering shorts, 2014) SEC 2014-09-16 $65k settled SEC v. Suttonbrook Capital Management LP (rule 105 offering shorts, 2014) SEC 2014-09-16 — settled SEC v. Troubh Partners LP (rule 105 offering shorts, 2014) SEC 2014-09-16 $107k settled SEC v. Vinci Partners Investimentos Ltda. (rule 105 offering shorts, 2014) SEC 2014-09-16 $142k settled SEC v. Whitebox Advisors LLC (rule 105 offering shorts, 2014) SEC 2014-09-16 $366k settled SEC v. Carmela Brocco (rule 105 offering shorts, 2014) SEC 2014-07-02 $129k settled SEC v. Derek W. Bakarich (rule 105 offering shorts, 2014) SEC 2014-07-02 $9.7k settled SEC v. Steven J. Niemis (rule 105 offering shorts, 2014) SEC 2014-07-02 $78.5k settled SEC v. Tina M. Lizzio (rule 105 offering shorts, 2014) SEC 2014-07-02 $17.3k settled SEC v. William W. Vowell (rule 105 offering shorts, 2014) SEC 2014-07-02 $30.9k settled SEC v. G-2 Trading LLC (rule 105 offering shorts, 2014) SEC 2014-05-22 $75k settled SEC v. Genesis Advisory Services Corp., ABJ Societe Anonyme Corp. and Bruce J. Fixelle (rule 105 offering shorts, 2014) SEC 2014-05-21 $492k settled SEC v. Ironbird Capital LLC (rule 105 offering shorts, 2014) SEC 2014-05-21 — settled SEC v. Worldwide Capital, Inc. and Jeffrey W. Lynn (rule 105 offering shorts, 2014) SEC 2014-03-05 $2.5m settled SEC v. Axius Holdings, LLC and Henry Robertelli (rule 105 offering shorts, 2014) SEC 2014-01-06 $26k settled SEC v. John Durrett (rule 105 offering shorts, 2014) SEC 2014-01-06 $26k settled SEC v. Blackthorn Investment Group, LLC (rule 105 offering shorts, 2013) SEC 2013-09-16 $260k settled SEC v. Claritas Investment, Ltd. (rule 105 offering shorts, 2013) SEC 2013-09-16 $65k settled SEC v. Credentia Group, LLC (rule 105 offering shorts, 2013) SEC 2013-09-16 $65k settled SEC v. D. E. Shaw & Co., L.P. (rule 105 offering shorts, 2013) SEC 2013-09-16 $202k settled SEC v. Deerfield Management Company, L.P. (rule 105 offering shorts, 2013) SEC 2013-09-16 $609k settled SEC v. G-2 Trading LLC (rule 105 offering shorts, 2013) SEC 2013-09-16 — unknown SEC v. Hudson Bay Capital Management LP (rule 105 offering shorts, 2013) SEC 2013-09-16 $272k settled SEC v. JGP Global Gestão de Recursos Ltda. (rule 105 offering shorts, 2013) SEC 2013-09-16 $514k settled SEC v. M.S. Junior, Inc. (rule 105 offering shorts, 2013) SEC 2013-09-16 $165k settled SEC v. Manikay Partners LLC (rule 105 offering shorts, 2013) SEC 2013-09-16 $680k settled SEC v. Meru Capital Group, LP (rule 105 offering shorts, 2013) SEC 2013-09-16 $131k settled SEC v. Merus Capital Partners, LLC (rule 105 offering shorts, 2013) SEC 2013-09-16 $65k settled SEC v. Ontario Teachers’ Pension Plan Board (rule 105 offering shorts, 2013) SEC 2013-09-16 $68.3k settled SEC v. Pan Capital AB (rule 105 offering shorts, 2013) SEC 2013-09-16 $221k settled SEC v. PEAK6 Capital Management LLC (rule 105 offering shorts, 2013) SEC 2013-09-16 $65k settled SEC v. Philadelphia Financial Management of San Francisco, LLC (rule 105 offering shorts, 2013) SEC 2013-09-16 $65k settled SEC v. Polo Capital International Gestão de Recursos Ltda. (rule 105 offering shorts, 2013) SEC 2013-09-16 $76k settled SEC v. Soundpost Partners, LP (rule 105 offering shorts, 2013) SEC 2013-09-16 $65k settled SEC v. Southpoint Capital Advisors LP (rule 105 offering shorts, 2013) SEC 2013-09-16 $170k settled SEC v. Talkot Capital LLC (rule 105 offering shorts, 2013) SEC 2013-09-16 $65k settled SEC v. Vollero Beach Capital Partners LLC (rule 105 offering shorts, 2013) SEC 2013-09-16 $215k settled SEC v. War Chest Capital Partners LLC (rule 105 offering shorts, 2013) SEC 2013-09-16 $130k settled SEC v. Western Standard, LLC (rule 105 offering shorts, 2013) SEC 2013-09-16 $65k settled SEC v. UBS O’Connor, LLC (rule 105 offering shorts, 2013) SEC 2013-06-03 $1.1m settled SEC v. Ardsley Advisory Partners (rule 105 offering shorts, 2013) SEC 2013-02-05 $253k settled