Jefferies Group (JEF) includes boilerplate copy warning investors that its employees may engage in misconduct that harms the investment bank’s reputation, exposes it to legal liabilities, and may result in regulatory penalties. The company also warns investors that employee misconduct may be difficult to detect.

In its latest 10-K, Jeffries warns of “significant” employee misconduct:

“The occurrence of significant employee misconduct could have a material adverse financial effect or cause us significant reputational harm and/or legal and regulatory liability, which in turn could seriously harm our business and our prospects.”

There are no accidents in SEC filings. Including the term “significant” is intentional. While we have no information about any wrongdoing, we are flagging this change for investors in the event that it foreshadows legal or regulatory action as a result of misconduct by one of the firm’s 3,922 employees.