On April 19, 2022, a $1.9 million fine was imposed as part of a judgment issued in the US District Court for the Eastern District of Michigan to resolve allegations that Bernard Compton, a former executive for Domino’s Pizza, was involved in multiple acts of insider trading between 2015 and 2020. In its April 13, 2022 complaint, the Securities and Exchange Commission charged Compton with insider trading for “repeatedly” purchasing Domino’s securities ahead of the company’s quarterly earnings announcements.
According to the complaint, Compton, who was responsible for preparing financial reports for Domino’s senior management from approximately April 2015 to July 2020, misused confidential material nonpublic information (MNPI) related to Domino’s financial performance to purchase securities prior to the company’s public release of earnings statements. The SEC alleged that, on 12 separate occasions, Compton purchased Domino’s stock options while in possession of MNPI – options that he sold for a profit following quarterly earnings announcements allowing him to realize more than $960,000 in unlawful gains.
The SEC’s complaint charged Compton with violating Section 10(b) of the Securities and Exchange Act of 1934 and Rule 10(b)5 thereunder for the unlawful trades, and without admitting or denying the allegations in the complaint, Compton agreed to the entry of the final judgment in order to settle the charges against him. As part of the judgment, Compton is permanently enjoined from committing further violations of the Exchange Act, and Compton agreed to pay a civil penalty totaling more than $1.9 million.