Defendant Name: The St. Joe Company

Defendant Type: Public Company
SIC Code: 6552
CUSIP: 79014810

Initial Case Details

Legal Case Name In the Matter of The St. Joe Company, Wm. Britton Greene, William S. McCalmont, Janna L. Connolly, CPA, J. Brian Salter, CPA, and Phillip B. Jones, CPA
First Document Date 27-Oct-2015
Initial Filing Format Administrative Action
File Number 3-16927
Allegation Type Issuer Reporting and Disclosure
AAER 3716

Violations Alleged

Exchange Act
• Rule 12b-20
• Sec 13(a)
• Rule 13a-1
• Rule 13a-11
• Rule 13a-13
• Sec 13(b)(2)(A)
• Sec 13(b)(2)(B)
Securities Act
• Sec 17(a)(2)
• Sec 17(a)(3)
Additionally, William Britton Greene is alleged to have caused The St. Joe Company's violation of Rule 12b-20 of the Exchange Act.
William S. McCalmont is alleged to have caused The St. Joe Company's violation of Rule 12b-20 of the Exchange Act.
Janna L. Connolly is alleged to have caused The St. Joe Company's violation of Rule 12b-20 of the Exchange Act.
J. Brian Salter is alleged to have caused The St. Joe Company's violation of Rule 12b-20 of the Exchange Act.
Phillip B. Jones is alleged to have caused The St. Joe Company's violation of Rule 12b-20 of the Exchange Act.
William Britton Greene is alleged to have caused The St. Joe Company's violation of Sec 13(a) of the Exchange Act.
William S. McCalmont is alleged to have caused The St. Joe Company's violation of Sec 13(a) of the Exchange Act.
Janna L. Connolly is alleged to have caused The St. Joe Company's violation of Sec 13(a) of the Exchange Act.
J. Brian Salter is alleged to have caused The St. Joe Company's violation of Sec 13(a) of the Exchange Act.
Phillip B. Jones is alleged to have caused The St. Joe Company's violation of Sec 13(a) of the Exchange Act.
William Britton Greene is alleged to have caused The St. Joe Company's violation of Rule 13a-1 of the Exchange Act.
William S. McCalmont is alleged to have caused The St. Joe Company's violation of Rule 13a-1 of the Exchange Act.
Janna L. Connolly is alleged to have caused The St. Joe Company's violation of Rule 13a-1 of the Exchange Act.
J. Brian Salter is alleged to have caused The St. Joe Company's violation of Rule 13a-1 of the Exchange Act.
Phillip B. Jones is alleged to have caused The St. Joe Company's violation of Rule 13a-1 of the Exchange Act.
William Britton Greene is alleged to have caused The St. Joe Company's violation of Rule 13a-11 of the Exchange Act.
William S. McCalmont is alleged to have caused The St. Joe Company's violation of Rule 13a-11 of the Exchange Act.
Janna L. Connolly is alleged to have caused The St. Joe Company's violation of Rule 13a-11 of the Exchange Act.
J. Brian Salter is alleged to have caused The St. Joe Company's violation of Rule 13a-11 of the Exchange Act.
Phillip B. Jones is alleged to have caused The St. Joe Company's violation of Rule 13a-11 of the Exchange Act.
William Britton Greene is alleged to have caused The St. Joe Company's violation of Rule 13a-13 of the Exchange Act.
William S. McCalmont is alleged to have caused The St. Joe Company's violation of Rule 13a-13 of the Exchange Act.
Janna L. Connolly is alleged to have caused The St. Joe Company's violation of Rule 13a-13 of the Exchange Act.
J. Brian Salter is alleged to have caused The St. Joe Company's violation of Rule 13a-13 of the Exchange Act.
Phillip B. Jones is alleged to have caused The St. Joe Company's violation of Rule 13a-13 of the Exchange Act.
William Britton Greene is alleged to have caused The St. Joe Company's violation of Sec 13(b)(2)(A) of the Exchange Act.
William S. McCalmont is alleged to have caused The St. Joe Company's violation of Sec 13(b)(2)(A) of the Exchange Act.
Janna L. Connolly is alleged to have caused The St. Joe Company's violation of Sec 13(b)(2)(A) of the Exchange Act.
J. Brian Salter is alleged to have caused The St. Joe Company's violation of Sec 13(b)(2)(A) of the Exchange Act.
Phillip B. Jones is alleged to have caused The St. Joe Company's violation of Sec 13(b)(2)(A) of the Exchange Act.
William Britton Greene is alleged to have caused The St. Joe Company's violation of Sec 13(b)(2)(B) of the Exchange Act.
William S. McCalmont is alleged to have caused The St. Joe Company's violation of Sec 13(b)(2)(B) of the Exchange Act.
Janna L. Connolly is alleged to have caused The St. Joe Company's violation of Sec 13(b)(2)(B) of the Exchange Act.
J. Brian Salter is alleged to have caused The St. Joe Company's violation of Sec 13(b)(2)(B) of the Exchange Act.
Phillip B. Jones is alleged to have caused The St. Joe Company's violation of Sec 13(b)(2)(B) of the Exchange Act.

Resolutions

First Resolution Date 27-Oct-2015
Headline Total Penalty and Disgorgement $3,811,064

Related Documents:

33-9967 27-Oct-2015 Administrative Proceeding
Order Instituting Public Administrative and Cease-and-Desist Proceedings Pursuant to Section 8A of the Securities Act of 1933, Sections 4C and 21C of the Securities Exchange Act of 1934, and Rule 102(e) of the Commission's Rules of Practice, Making Findings, and Imposing Remedial Sanctions, Cease-and-Desist Orders and Penalties
On October 27, 2015, the SEC instituted settled administrative and cease-and-desist proceedings against The St. Joe Company, Wm. Britton Greene, William S. McCalmont, Janna L. Connolly, CPA, J. Brian Salter, CPA, and Phillip B. Jones, CPA. According to the SEC with respect to The St. Joe Company: "The underlying improper conduct comprised, first, failing in two respects to comply with Generally Accepted Accounting Principles ('GAAP') in the impairment testing of the Company's real estate development assets; second, after discovering the broader of the aforementioned GAAP lapses in October 2010, (i) failing to identify or correct any resulting errors in prior-period financial statements and (ii) improperly using assumptions based on conditions not existing as of the quarter ended September 30, 2010 in conducting that quarter's impairment testing for certain real estate developments; third, applying an unreasonable sales price assumption to undeveloped beachfront land in one of the Company's largest real estate developments in the fourth quarter of 2010; and fourth, failing to specifically disclose, in its 2010 Form 10-K, that the Company decided not to proceed with the material development and planning of two of its largest real estate developments, and had instead determined to bulk-sell the related undeveloped land in the future."

Other Defendants in Action:

William Britton Greene
William S. McCalmont
Janna L. Connolly
J. Brian Salter
Phillip B. Jones

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