On March 3, 2010, the SEC filed a complaint against American Equity Investment Life Holding Company, David J. Noble, and Wendy C. Waugaman alleging that a proxy statement filed by the company in September 2006 was "materially misleading because it failed to properly disclose these financial benefits to Noble, as required by commission regulations."

On March 3, 2010, the SEC charged American Equity Investment Life Holding Company (“American Equity”) and two of its executives—the former CEO and current chairman David Noble (“Noble”) and the former CFO and current CEO Wendy Waugaman (“Waugaman”)—with proxy disclosure violations. The case involves the company’s 2006 proxy statement disclosures relating to its acquisition of a financing company wholly-owned by Noble, in which Noble received a $2.5 million distribution from the acquired company. According to the SEC’s complaint filed in federal court in Des Moines, American Equity failed to disclose that the acquired company had a large deficit at the time of the distribution and that this acquisition of Noble’s company effectively relieved him of substantial potential personal liability for the acquired company’s debts. American Equity, Noble, and Waugaman agreed to settle the charges against them without admitting or denying the allegations of the SEC’s complaint. Under the settlement, Noble, Waugaman, and American Equity agreed to be permanently enjoined from committing future violations of the provisions of the federal securities laws that prohibit materially false or misleading statements or omissions in proxy statements. Additionally, Noble will pay a $900,000 penalty, and Waugaman will pay a $130,000 penalty. American Equity also has agreed to certain undertakings in connection with the settlement.

The Court stated: "The Securities and Exchange Commission having filed a Complaint and Defendants American Equity Investment Life Holding Company ("American Equity"), David J. Noble, and Wendy C. Waugaman having entered general appearances; consented to the Court's jurisdiction over them and the subject matter of this action; consented to entry of this Final Judgment without admitting or denying the allegations of the Complaint (except as to jurisdiction); waived findings of fact and conclusion of law; and waived any right to appeal from this Final Judgment"