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.
On July 20, 2023, the SEC published an order of settlement between it and the registrant relating to registrant's failure to timely file amended reports on schedule 13G related to certain special purpose acquisition Company ("SPAC") related investments, to timely disclose conflicts of interest related to client investments in SPACS, and to adopt reasonably designed policies and procedures regarding its personnel's ownership interests in SPAC sponsors. Without admitting or denying the findings, registrant consented to the entry of the SEC'S order finding that registrant violated Sections 206(2) and 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-7 thereunder, and violated and ...