The SEC alleges that Davis used what it terms "cookie jar" reserves to cover shortfalls in operating results, along with using other reserve manipulations in those years. Davis agreed to pay a $175,000 penalty, along with disgorgement and pre-judgment interest of $28,158. Inhoff was charged with aiding and abetting the improper accounting and agreed to pay a $25,000 penalty and the similar payments of $19,049. Davis became CFO of CA Technologies, the former Computer Associates, in 2005 but he left under mutual agreement a year later.

The fraudulent accounting made it appear that Dell consistently met Wall Street earnings targets, the complaint said. The company also allegedly used reserve manipulation to misstate operating expenses as a percent of revenue, which the SEC said Dell used as a metric for investors. It also allegedly misstated operating income for its Europe, Middle East and Africa segment.

The two men agreed to the settlements but did not admit or deny the allegations and both were suspended from practicing before the SEC as accountants, Davis for five years and Imhoff for three years.

The separate charges against the company involved omissions regarding aspects of its commercial relationship with Intel and other accounting and financial reporting matters for fiscal 2008. The settlement with Michael Dell involved negligence and no allegation of fraudulent intent and his ability to serve as an officer of a public company was not impacted.