Venable Corporation has seven hundred and fifty thousand shares of common stock outstanding, which are owned by 2,640 shareholders. The assets of Venable Corporation are valued at more than $10 million. In March, Underhill began purchasing shares of Venable’s common stock in the open market. By April, he had acquired forty thousand shares at prices ranging from $12 to $14. Upon discovering Underhill’s activities in late April, the directors of Venable had the corporation purchase the forty thousand shares from Underhill for

$18 per share. Explain which provisions of the 1934 Act, if any, have been violated.