SEC v. Tod A. Ditommaso, Esq. (unregistered distributions, 2017)

Judgment entered

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In 2017 an SEC administrative law judge found attorney Tod A. DiTommaso violated Section 5 by issuing Rule 144 opinion letters, ordering $1,475 in disgorgement and a $1,475 penalty.

The record

What was ordered

Civil penalty

$1.5k

Disgorgement

$1.5k

Prejudgment interest

—

Total relief

$3k

Alleged gain

—

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

What is alleged to have happened

On June 13, 2017 an SEC administrative law judge issued an initial decision against attorney Tod A. DiTommaso, concluding he violated Securities Act Sections 5(a) and 5(c) through ten opinion letters in 2012 and 2013 on the Rule 144 safe harbor for stock of Fusion Pharm, Inc., and ordering $1,475 in disgorgement and a $1,475 penalty. The record previously omitted the penalty. The decision was later superseded after the Lucia ruling.

This library tags the matter as unregistered distributions, based on the conduct the document describes. The tagging is ours, not the regulator's: agencies charge statutory provisions, not technique names.

For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the release.

What technique is this, and how does it work?

This action is tagged with one technique in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.

• Unregistered distributions — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2017-06-13 Initial decision

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

• Initial decision (ID-1142)
• Order instituting proceedings
• Finality order

The linked release is a work of the United States government and is not subject to copyright. Our summary and narrative above are our own writing.

Same matter

The library links these 3 records because they appear to concern one matter: the same lead defendant, an overlapping technique tag and close filing dates, or a shared court docket or a release that cites the other. Records are listed by date filed.

This grouping is the library's, made by matching names, techniques, dates and citations when the site is built. It is not the regulator's or a court's determination that the records are one case, and it errs towards missing a link rather than making a false one.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added September 10, 2026. submit a correction.