Section 13(d) of the Securities Exchange Act of 1934 and the rules thereunder impose various reporting requirements on persons that beneficially own more than 5% of a public issuer’s securities, including pledges of those securities as collateral. Additionally, issuers are required to report pledges of their securities by their officers and directors. The SEC sanctioned activist investor Carl C. Icahn and Icahn Enterprises L.P. (IEP) for violating those requirements. Although Icahn had originally disclosed, on Schedule 13D, his acquisition of IEP and certain subsequent pledges of its securities to secure margin loans, he allegedly never disclosed multiple subsequent pledges. Also, IEP allegedly failed to disclose Icahn’s pledges in its annual reports. This article details the alleged reporting failures and the terms of the settlements. See “Shorter Filing Deadlines for Schedules 13D and 13G and Other Beneficial Ownership Rule Changes” (Jan. 4, 2024); as well as our two-part series “SEC Proposes Comprehensive Changes to Beneficial Ownership Rules”: Part One (Apr. 21, 2022); and Part Two (Apr. 28, 2022).