As evidence of his intent, the complaint points to an email Cohen sent to Wells Fargo's CEO in February 2018 to advocate for a seat on the Wells Fargo board and to make suggestions about how Wells Fargo could improve operations. 4 According to the complaint, these conversations between Cohen and the Wells Fargo CEO continued through at least April 2020 while Cohen made additional open market purchases of Wells Fargo voting securities. The complaint notes that, because open market acquisitions require an affirmative decision by the acquiring person to make the purchase, Cohen's failure to submit an HSR notification cannot be attributed to excusable negligence. Cohen will pay a civil penalty of $985,320 to settle the charges. This amounts to a daily civil penalty of approximately $927 for the nearly three-year span between the date Cohen acquired Wells Fargo voting securities in excess of the HSR thresholds and the date the HSR waiting period expired for his corrective filing.