On September 30, 2020, the Securities and Exchange Commission (SEC) entered a cease-and-desist order against a registrant for failure to disclose approximately $1.7 million in travel-related perquisites and personal benefits provided to named executive officers during 2015-2018. The perquisites included expenses associated with the CEO’s personal use of corporate aircraft and executives’ expenses associated with hotel stays, as well as related taxes. The order found violations of Sections 13(a) and 14(a) of the Exchange Act and imposed a $600,000 civil penalty. The accompanying press release notes the SEC “will continue to use risk-based analytics to identify companies that fail to comply with the Commission’s executive compensation rules.”

The disclosure of executive perquisites remains a focus of the SEC, as seen in other recently announced settlements and the September 21, 2020 Compliance and Disclosure Interpretation on the disclosure of perquisites related to COVID-19.