Settlement base amount is calculated using statutory minimum penalties, applicant multipliers, and aggregation rules for multiple defaults.

Base Amount for settlement is determined by applying the minimum statutory penalty for the relevant default and the applicable applicant-category multiplier. It is calculated for each count of default and aggregated, with the highest amount used where one default triggers multiple violations and separate amounts added for distinct defaults. The amount is doubled for a lead conspirator, and an independent director may be treated as an executive director where alleged or found to have benefited from or actively participated in fraud. The Base Amount cannot be below an imposed penalty.

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