Federal Contractor Misconduct Database (FCMD)

The federal government routinely awards contracts to companies with histories of misconduct, including contract fraud and other violations. POGO believes that providing this website will help to improve contracting decisions and increase public knowledge of how the government spends billions of taxpayer dollars each year. Read more…

SEC v. Imhoff and Davis (Accounting Irregularities)

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”).

Misconduct Type
Enforcement Agency
Contracting Party
Court Type
Date of Filing
Contractors Involved Penalty
Dell, Inc. $247,207
Further Information Released
Davis Complaint 11/23/2010
Imhoff Complaint 11/23/2010
SEC Press Release 11/23/2010

Federal Contractor Misconduct Database