On March 18, 2014, FINRA and BATS Exchange, Inc. (“BATS”) announced that they had jointly concluded an enforcement action under which Citigroup Global Markets Inc. (“Citigroup”) agreed to pay approximately $1.1 million for short sales made in advance of five IPOs in violation of Rule 105 of Regulation M under the Exchange Act, which generally prohibits purchasing securities in public offerings when the purchaser has sold the securities short within a certain amount of time prior to the pricing of the offering. In concluding this settlement, Citigroup neither admitted nor denied the charges, but consented to the entry of FINRA and BATS’ findings. This enforcement action follows earlier actions taken by the SEC, which announced on September 16, 2013 that it had charged over 20 firms with violations of Rule 105. For a discussion of these cases, please see our September 30, 2013 Alert.