Additionally, the order alleges that the former audit partner failed to maintain independence from his audit client by engaging in prohibited human resource services for Mattel, including ranking candidates for management positions. The settlement with Mattel includes findings that the company violated the negligence-based antifraud provisions of the Securities Act and the reporting, books and records, and internal controls provisions of the Exchange Act. Without admitting or denying these findings, Mattel agreed to a cease-and-desist order and to pay a $3.5 million civil penalty. The order also notes that, in settling, the SEC took into account Mattel's cooperation with the SEC's investigation and its remediation efforts, including Mattel's prompt response to the whistleblower complaint, immediate termination of its senior notes offering, prompt instigation of an internal investigation, and restatement of its financials just three months after being made aware of the whistleblower complaint.