The SEC charged a company and its founder and former CEO and board chair for failure to disclose perks and related party transactions in accordance with Items 402 and 404 of Regulation S-K in violation of the federal securities laws. As was the case with another relatively recent perks enforcement action (we reported on here), the SEC’s Orders highlight the importance of (among other things) accurate and complete D&O Questionnaires to facilitate compliance with the SEC’s disclosure requirements. The company and founder / former CEO were fined $1 million and $100,000, respectively, in civil penalties.