In December 2004, First Command entered into a $12 million settlement with the SEC and NASD without admitting guilt. As part of the settlement, First Command agreed to offer restitution to all clients who had purchased and sold a systematic plan between 1999 and 2004, establishment of educational programs, and monitoring or prefiling. People who had not terminated their systematic plan were not covered in the settlement. In September 2007, a California judge granted "Class Action" status to a 2005 lawsuit filed by systematic plan holders whose plans were active when the SEC issued its ruling on December 15, 2004. In October 2008, attorneys for the plaintiffs sought court approval for a settlement. The settlement was approved by the court in April 2009.