Putnam has said it would reimburse the funds in which managers traded improperly.

There are no indications that MFS executives improperly traded their own funds.

The company has since acknowledged that additional employees traded improperly, and, as of the end of last year, fired a total of 15 employees, the S.E.C. said.

Canary improperly traded funds managed by Strong, according to the complaint, as well as funds managed by Bank of America, Bank One and Janus.

Mr. Spitzer vowed in October to bring charges against Mr. Strong, contending that he improperly traded in and out of the shares of his company's funds.

All three denied participating in a scheme by which lawmakers or members of their staffs improperly traded stamps for cash.

And Merrill notified DuPont that DuPont employees might have been trading improperly in two of those funds.

Fund companies that have said they will refund fees on money traded improperly in their funds may have trouble calculating reimbursements, given the frenetic pace of the traders' activity.

The complaint said that Mr. Gordon allowed Mr. Stern to trade in and out of the bank's funds quickly and improperly.

That meeting was one of several heavily criticized by Republicans and campaign finance reform advocates, who said that the Democratic Party improperly traded access for campaign donations.