Regulatory action by US Securities and Exchange Commission: cease and desist
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 alleged that, in 2016, registrant's written policies and procedures regarding the prevention of misuse of potentially material nonpublic information were not sufficiently implemented and enforced in certain circumstances when registrant had an employee serving on the Board of directors of a public Company in which one of registrant's Funds was invested. Pursuant to an offer of settlement, the SEC found, and the registrant neither admitted nor denied, that the registrant violated Sections 204a and 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-7 thereunder.