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Firm commitment offering

In a firm commitment offering the underwriters agree to buy the whole issue from the seller and resell it, taking the risk that it will not all sell. Rule 105 applies only to offerings conducted on this basis.

manipulation techniques · updated 2026-09-20

Where does firm commitment offering come up?

This term is used in the following manipulation techniques, each explained in full on its own page.

Enforcement actions involving these techniques

Action Agency Filed Technique Penalty Status
SEC v. Sourcerock Group, LLC (rule 105 offering shorts, 2025) SEC 2025-08-04 Rule 105 Offering Shorts $250k settled
SEC v. Snow Lake Capital (HK) Limited (rule 105 offering shorts, 2024) SEC 2024-12-19 Rule 105 Offering Shorts $525k settled
SEC v. FiveT Capital AG (rule 105 offering shorts, 2024) SEC 2024-11-26 Rule 105 Offering Shorts $805k settled
SEC v. Centerline Investment Management Limited (rule 105 offering shorts, 2024) SEC 2024-09-23 Rule 105 Offering Shorts $112k settled
SEC v. Gates Capital Management, Inc. (rule 105 offering shorts, 2024) SEC 2024-09-17 Rule 105 Offering Shorts $57.6k settled

See also

Terms that refer here

Follow-on offering

Back to the full glossary — 261 defined terms.