Regulatory action by US Securities and Exchange Commission: civil penalty
Fund concerned: none named in the filing. The matter concerns the adviser itself, not a specific fund, and none of the insurance-dedicated funds in this file is named.
The SEC found that between March 2020 and May 2020, when the coronavirus pandemic disrupted the U.S. Financial Markets, Madison Capital funding LLC ("Madison Capital"), a predecessor firm to Apogem Capital, did not price principal trades made with Funds it advised at fair Market value, contrary to its representations to investors. Without admitting or denying the SEC'S findings, Madison Capital agreed to pay a civil money penalty in the amount of $900,000 and consented to a cease and desist order that included a censure.