April 30, 2018

William "Billy" Walters, Thomas C. Davis

Trading and Pricing

SANCTION AMOUNT: 22556858.46

Defendants: William "Billy" Walters, Thomas C. Davis

Davis was a board member of Dean Foods Company and he owed Walters money. In exchange for assistance with his financial debts, Davis regularly shared inside information about Dean Foods with Walters in advance of market-moving events, using prepaid cell phones and other methods in an effort to avoid detection. This sanction represents disgorgement and prejudgment interest agreed to by Walters. Both men were also criminally convicted.

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