On January 27, 2015, the SEC instituted administrative and cease-and-desist proceedings against Oppenheimer & Co., Inc. According to the SEC: "Oppenheimer engaged in two separate courses of conduct, the first during the period July 2008 through May 2009 ('Oppenheimer I') and the second during the period October 2009 through December 2010 ('Oppenheimer II'), each of which violated the federal securities laws." The SEC stated that: "A penalty amount that includes an additional $10 million is appropriate for the conduct at issue herein, however, in light of the civil money penalty paid by Oppenheimer to FinCEN in In the Matter of Oppenheimer & Co., Inc., Number 2015-01, no additional penalty is being ordered at this time."