Susan Dudley, Chief Compliance Officer (NONE), bought 2,444 shares at $9.00 ($22K) on 2012-10-16, disclosed to the SEC on 2012-10-18.
Open-market purchase of $22k NONE by Chief Compliance Officer. Below the thresholds we flag for high-conviction alerts (no C-suite role, rare reversal, cluster, or A-grade history).