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, prior to July 2022, registrant's written policies and procedures regarding the prevention of misuse of potentially material non-public information were not sufficiently implemented and enforced in certain circumstances when registrant traded the tranches of collateralized loan obligations it managed. The SEC noted that registrant conducted compliance reviews prior to trades in tranches of collateralized loans after July 2019, but alleged that registrant had not established, maintained or enforced written policies and procedures in respect of such reviews prior to July 2022. The SEC also alleged that, prior to June 2024, registrant's written policies and procedures ...