UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934 

Release No. 98922 / November 14, 2023

ADMINISTRATIVE PROCEEDING

File No. 3-20963

In the Matter of

Eagle Bancorp, Inc.,

Respondent.

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ORDER APPOINTING FUND 

ADMINISTRATOR, SETTING 

ADMINISTRATOR’S BOND 

AMOUNT, AND AUTHORIZING 

PAYMENT OF FEES AND 

EXPENSES

On August 16, 2022, the Commission issued a Corrected Order Instituting Cease-andDesist Proceedings, Pursuant to Section 8A of the Securities Act of 1933 and Section 21C of the 

Securities Exchange Act of 1934, Making Findings, and Imposing a Cease-and-Desist Order (the 

“Order”)1against Eagle Bancorp, Inc. (“Eagle” or “Respondent”). In the Order, the Commission 

found that Eagle made material misstatements and omissions about related party loans that 

Eagle’s principal subsidiary, EagleBank, extended to family trusts affiliated with Eagle’s former 

Chairman, CEO, and President, Ronald D. Paul (“Paul”), and to other related parties. From 

March 2015 through April 2018, Eagle failed to include these undisclosed loans in the related 

party loan balances included in its annual reports and proxy statements filed with the 

Commission. Eagle and Paul also made false statements regarding the nature of the loans in two 

press releases. Based on this conduct, the Commission found that Eagle violated Sections 

1

 Securities Act Rel. No. 11092 (Aug. 16, 2022).
2

17(a)(2) and 17(a)(3) of the Securities Act, and Sections 13(a), 13(b)(2)(A), 13(b)(2)(B) and 

14(a) of the Exchange Act and Rules 12b-20, 13a-1, and 14a-9 thereunder.

The Commission ordered Eagle to pay $2,600,000 in disgorgement, $750,493 in 

prejudgment interest, and a $10,000,000 civil money penalty, for a total of $13,350,493, to the 

Commission. In its order, the Commission also created a Fair Fund, pursuant to Section 308(a) 

of the Sarbanes-Oxley Act of 2002, so the penalties paid, along with the disgorgement and 

interest paid, could be distributed to harmed investors (the “Fair Fund”). The Commission 

further ordered that the Fair Fund may be combined with any fund established for the benefit of 

harmed investors in SEC v. Ronald D. Paul, 22-cv-06985 (S.D.N.Y.) (the “Related Action”).

2

The Fair Fund consists of the $13,350,493 collected from the Respondent in this matter 

and the $431,216 collected in the Related Action. The Fair Fund has been deposited in a 

Commission-designated account at the U.S. Department of the Treasury, and any accrued 

interest will be added to the Fair Fund.

The Division of Enforcement (the “Division”) now seeks the appointment of JND Legal 

Administration (“JND”) as the fund administrator and requests that the administrator’s bond be 

set at $13,781,709. JND is included in the Commission’s approved pool of administrators. The 

Division further requests that the Commission authorize the Office of Financial Management 

(“OFM”), at the direction of an Assistant Director of the Office of Distributions, to pay the Fund 

Administrator’s fees and expenses from the Fair Fund, so long as the total amount paid to the 

Fund Administrator, including the invoice to be paid, does not exceed the total amount of the 

approved cost proposal submitted by the Fund Administrator.

2

 The Commission corrected the Order to add this language, which was inadvertently omitted at the time of 

issuance. The Fair Fund has received $431,216.00 from the Related Action in accordance with the Court’s Order 

dated October 11, 2023. See Dkt. No. 16, SEC v. Ronald D. Paul, 22-cv-06985 (S.D.N.Y.).
3

Accordingly, IT IS HEREBY ORDERED that:

A. JND is appointed as the Fund Administrator pursuant to Rule 1105(a) of the 

Commission’s Rules on Fair Fund and Disgorgement Plans (“Commission’s 

Rules”);3

B. JND shall obtain a bond in accordance with Rule 1105(c) of the Commission’s 

Rules4in the amount of $13,781,709;

C. the Fund Administrator will submit invoices to the Commission staff for services 

rendered, in accordance with Rule 1105(d) of the Commission’s Rules;5and 

D. at the direction of an Assistant Director of the Office of Distributions, OFM is 

authorized to pay the Fund Administrator’s fees and expenses from the Fair Fund, 

in accordance with Rule 1105(e) of the Commission’s Rules,6so long as the total 

amount paid to the Fund Administrator, including the invoice to be paid, does not 

exceed the total amount of the approved cost proposal submitted by the Fund 

Administrator.

For the Commission, by the Division of Enforcement, pursuant to delegated authority.7

Vanessa A. Countryman

Secretary 

3

 17 C.F.R. § 201.1105(a).

4

 17 C.F.R. § 201.1105(c).

5

 17 C.F.R. § 201.1105(d).

6

 17 C.F.R. § 201.1105(e).

7

 17 C.F.R. § 200.30-4(a)(17) and 17 C.F.R. § 200.30-4(a)(21)(vi).