For those broker-dealers that did not self-report by the November deadline, the initiative threatens substantial sanctions if they are later found to be not in compliance with the Customer Protection Rule. To emphasize this regulatory risk, the SEC simultaneously announced a settled order with Merrill Lynch, Pierce, Fenner & Smith Incorporated for Customer Protection Rule violations in which Merrill Lynch admitted to the misconduct and paid $415 million in the form of a civil penalty, disgorgement, and prejudgment interest for (i) engaging in complex options trades that did not have any economic basis but reduced the required deposit of customer cash in its reserve account, which allowed Merrill Lynch to use that customer cash to finance its own trading activities and (ii) holding customer securities in accounts that were subject to liens. [24] If Merrill Lynch had not retained an independent consultant prior to the settlement, the order would have also required it to do so as an undertaking.