The Securities and Exchange Commission had an unusually busy first fiscal quarter, but collected monetary payments in fewer cases than normal.

That’s according to a NERA Economic Consulting report detailing Q1 SEC Settlements Trends, which shows that the commission settled with 205 defendants in its first quarter of fiscal year 2010, compared to 181 in the previous quarter and 123 in the first fiscal quarter of 2009. (The SEC’s fiscal year starts on Oct. 1.)

The uptick is notable because the first quarter is typically a slow time for SEC settlements.

“In general, the first quarter is typically the quarter with the fewest settlements, and the end of the fiscal year tends to be a very active period with a lot of settlements,” Elaine Buckberg, NERA senior vice president and one of the report’s authors, tells Compliance Week.

Since the passage of the Sarbanes Oxley Act in 2002, Buckberg notes that there’s only been one other fiscal year where settlements were higher in the first quarter than in the prior quarter—2007.

Buckberg offers two primary explanations for the jump. One is that the SEC is “cleaning house” and getting rid of old cases that weren’t that strong, which would explain why many didn’t involve financial payments. If that’s the case, Buckberg says, “Then we would expect a return to normal Q2 settlement levels and a return to a higher percentage of company settlements involving financial payments.” However, that could take more than one quarter.

Another possibility: As part of stricter enforcement efforts, the SEC is tackling and settling more cases, which Buckberg says may mean more cases with weaker merits that don’t result in penalties. “If we see continuing higher levels of settlements and continuing lower levels of company settlements involving payments, that would bear out the theory that they’re casting a wider net to tighten enforcement.”

Also notable is the number of zero-dollar company settlements in the first quarter of 2010. Just 41 percent of company settlements during the quarter involved some form of monetary payment—the third-lowest in any quarter since the passage of SOX and far less than the 56 percent rate for the period from the fourth quarter of 2002 through Q4 of 2009. For individuals, 58 percent of settlements in the quarter included a payment, which NERA notes is consistent with recent levels.

While the number of settlements during the quarter was large, the amount of those settlements was generally modest. Among companies with settlements that included a monetary payment, both the average and median settlement amount for the quarter were down from fiscal 2009 levels. The median company settlement of $400,000 was the fourth lowest of any quarter since the passage of SOX and well below the $1 million median for fiscal 2009, while the $4.7 million average company settlement was the fifth lowest over the same period, and far less than the $10.8 million average for fiscal 2009.

For individuals whose settlements included a monetary payment, the median settlement amount was approximately $120,000. That’s compared with a range in the annual median from $100,000 to $133,000 since fiscal 2003. The average individual settlement was $730,000 for the quarter, compared to a range of annual average of $1 million to $3.7 million since fiscal 2003.

Only four of the 10 largest settlements for the quarter exceeded $10 million. The largest was a $43.7 million settlement in November with Value Line Inc., which was accused of misappropriating assets from mutual funds that it advised. The smallest among the 10 was a $3 million December settlement with Investools, Inc. related to alleged misrepresentations to customers.

The data excludes settlements relating to failure to file periodic financial statements with the SEC, administrative proceedings barring accountants because of felony convictions, and administrative proceedings barring brokers, dealers, and accountants for practicing while unregistered.