UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION
Securities Exchange Act of 1934
Release No. 48476 /September 11,2003
Accounting and Auditing Enforcement
Release No. 1856 / September 11, 2003
Administrative Proceeding
File No. 3-11253
_________________________________________________________________
In the Matter of
LOUIS LUCULLO,
Respondent
_________________________________________________________________
ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS, MAKING FINDINGS, AND
IMPOSING A CEASE-AND-DESIST ORDER PURSUANT TO SECTION 21C OF THE
SECURITIES EXCHANGE ACT OF 1934 AS TO LOUIS LUCULLO
I.
The Securities and Exchange Commission ("Commission") deems it
appropriate that public administrative proceedings be, and hereby are,
instituted against Louis Lucullo ("Lucullo") pursuant to Section 21C
of the Securities Exchange Act of 1934 (the "Exchange Act").
II.
In anticipation of the institution of these administrative
proceedings, Lucullo has submitted an Offer of Settlement ("Offer"),
which the Commission has determined to accept. Solely for the purpose
of these proceedings and any other proceedings brought by or on behalf
of the Commission or to which the Commission is a party, and without
admitting or denying the findings contained herein, except as to the
Commission's finding of jurisdiction over Lucullo and the subject
matter of this proceeding, which Lucullo admits, Lucullo consents to
the issuance of this Order Instituting Cease-and-Desist Proceedings,
Making Findings, and Imposing a Cease-and-Desist Order Pursuant to
Section 21C of the Securities Exchange Act of 1934 as to Louis Lucullo
("Order") and to the entry of the findings and imposition of relief
SNIPPETS:
SECURITIES AND EXCHANGE COMMISSION
ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS, MAKING FINDINGS, AND IMPOSING A
The Securities and Exchange Commission deems it appropriate that public administrative
This case involves the issuance of a purported insurance policy by American International
As a result, Brightpoint's 1998 financial statements, as reported in the 1998 Form 10-K,
As set forth in separate orders issued today, the Commission has found that both Brightpoint
Lucullo was an assistant vice president of AIG's Loss Mitigation Unit, and he was AIG's
In the course of the Commission's investigation, and from his first opportunity, Lucullo
In determining to accept Lucullo's offer of settlement, the Commission has taken into
For the reasons set forth below, the Commission finds that Lucullo was a cause of
Lucullo, age 32, is a resident of New York, New York.
AIG is a holding company that, through its subsidiaries, is engaged in a broad range of
The first part purported to cover retroactively all of the extra UK losses up to $15 million
To minimize scrutiny by Brightpoint's auditors, Delaney, Harcharik and Lucullo designed both
On November 13, 2001, Brightpoint announced a restatement, which treated the AIG Policy as
On January 31, 2002, Brightpoint announced that it would further restate its financial
Rule 12b-20, which applies to all reports filed pursuant to Section 13 of the Exchange Act,
To produce, without service of a notice or subpoena, any and all documents and other
In determining whether to accept the Offer, the Commission has considered these undertakings.
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