Firm commitment offering
In a firm commitment offering the underwriters agree to buy the whole issue from the seller and resell it, taking the risk that it will not all sell. Rule 105 applies only to offerings conducted on this basis.
Where does firm commitment offering come up?
This term is used in the following manipulation techniques, each explained in full on its own page.
Enforcement actions involving these techniques
| Action | Agency | Filed | Technique | Penalty | Status |
|---|---|---|---|---|---|
| SEC v. Sourcerock Group, LLC (rule 105 offering shorts, 2025) | SEC | 2025-08-04 | Rule 105 Offering Shorts | $250k | settled |
| SEC v. Snow Lake Capital (HK) Limited (rule 105 offering shorts, 2024) | SEC | 2024-12-19 | Rule 105 Offering Shorts | $525k | settled |
| SEC v. FiveT Capital AG (rule 105 offering shorts, 2024) | SEC | 2024-11-26 | Rule 105 Offering Shorts | $805k | settled |
| SEC v. Centerline Investment Management Limited (rule 105 offering shorts, 2024) | SEC | 2024-09-23 | Rule 105 Offering Shorts | $112k | settled |
| SEC v. Gates Capital Management, Inc. (rule 105 offering shorts, 2024) | SEC | 2024-09-17 | Rule 105 Offering Shorts | $57.6k | settled |