The U.S. Securities and Exchange Commission (SEC) charged Dell’s former assistant controller, Randall D. Imhoff, and former chief accounting officer, Robert W. Davis, with taking part in improper accounting practices that led to the restatement of Dell’s financial results from 2003 through 2006. According to the SEC, Davis materially misrepresented Dell’s financial results by using various “cookie jar” reserves to cover shortfalls in operating results and engaged in other reserve manipulations from FY2002 to FY2005, and Imhoff aided and abetted the improper use of “cookie jar” reserves and other reserve manipulations to cover shortfalls in Dell’s operating results from FY2002 to FY2004. Without admitting or denying the SEC’s allegations, Davis agreed to pay a $175,000 penalty and $28,000 in disgorgement and pre-judgment interest to settle the charges; Imhoff agreed to pay a $25,000 penalty and $19,000 in disgorgement and pre-judgment interest. In July 2010, Dell and several current and former executives agreed to pay over $111 million to settle charges in the matter (see Dell, Inc. instance “Accounting Irregularities”).