Settlement base amount methodology applies applicant multipliers, aggregated defaults, and enhanced treatment for lead conspirators and culpable independent directors.

Settlement base amount is calculated by applying applicant-specific multipliers to the minimum applicable penalty and cannot be below an imposed penalty. Amounts are calculated and aggregated for each count of default, while a single default attracting multiple violations takes the higher applicable amount. The base amount is doubled for a lead conspirator, mastermind or key operator, and an independent director is treated as an executive director where implicated in benefiting from or actively participating in fraud. Specified conduct may be treated as one count, subject to adjustment of default counts based on case facts.

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