World Acceptance Corporation ("WAC"), headquartered in South Carolina, was a consumer loan company whose common stock was registered with the SEC and traded on the Nasdaq. At the time of the misconduct, WAC operated in Mexico through its wholly owned subsidiary, WAC de Mexico, S.A. de C.V. WAC sold WAC de Mexico on July 1, 2018, and currently does not have any foreign subsidiaries or conduct any business internationally.
In a filing on June 14, 2017, WAC announced that it would be unable to file its 10-K on time because it had begun an internal FCPA investigation in March 2017 into its operations in Mexico, focusing on certain payments related to loans, the maintenance of the Company’s books and records associated with such payments, and the treatment of compensation matters for certain employees. The internal investigation was begun after its independent accounting firm received an anonymous letter alleging compliance issues at the company.
The company hired Womble Carlyle Sandridge & Rice, LLP, as its outside legal counsel and Ernst & Young LLP to lead the investigation.
WAC also disclosed that it had voluntarily contacted the SEC and DOJ to advise both agencies that an internal investigation was underway. In its August 8, 2017 10-Q, the company disclosed that the SEC had issued a formal order of investigation, and in its November 8, 2018 10-Q, the company confirmed that it had been cooperating with both the DOJ and SEC.
In its 10-Q filed on February 10, 2020, WAC disclosed that it was in negotiations with the SEC to resolve that agency's investigation. The company said it had proposed a settlement in January 2020 that included a payment of $8 million, and the company accrued that amount at the end of 2019. In its 8-K filed on March 13, 2020, however, WAC disclosed that its settlement negotiations with the SEC had progressed sufficiently to accrue $21.7 million instead.
On August 5, 2020, the DOJ issued a declination letter to WAC stating that it had closed its investigation into the company. The DOJ cited the company's self-disclosure, full cooperation, and full remediation.
On August 6, 2020, the SEC resolved its investigation with an administrative proceeding against WAC.
