The Securities and Exchange Commission brought an administrative action against Wilmington Trust Corporation claiming that Wilmington Trust Company, its retail bank and commercial subsidiary, failed in 2009 and 2010 to accurately keep track of loans it granted to finance construction projects that were not repaid timely when the underlying projects experienced difficulties. These were typically matured loans that were 90 or more days past due. As a result, Wilmington Trust filed financial statements with the SEC that the agency claims were not accurate for multiple quarters in 2009 and 2010 and therefore were false and misleading. Financial statements filed with the SEC during 2009 were incorporated by reference into offering materials used by Wilmington Trust in connection with a 2010 public offering. Without admitting or denying any of the SEC’s findings, Wilmington Trust agreed to pay US $18.5 million in disgorgement and interest to settle this matter.