URITIES EXCHANGE ACT OF 1934 AND COMMISSION STATEMENT ON THE RELATIONSHIP OF COOPERATION TO AGENCY ENFORCEMENT DEcISIONS, SEC Rel. Nos. 34-44969 and AAER-1470 (Oct. 23, 2001) [hereinafter Seaboard Report] available at http ://www.sec.gov/litigation/ investreport/ 34-44969. htm. °US. SEC. AND EXCHANGE CoMM.