Venable Corporation has 750,000 shares of common stock outstanding, which are owned by 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. Which provisions of the 1934 Act, if any, have been violated?