A Compilation of Enforcement and Non-Enforcement Actions

by Foley & Lardner LLP


  • Cost of Proposed User Fees by Registered Investment Advisers Further Discussed
  • SEC Valuation Guidance for All Funds
  • Update on Insider Trading in Mutual Fund Shares


  • Failure to Disclose Conflict of Interest to Clients Results in SEC Enforcement Proceeding Against Registered Investment Adviser
  • Adviser’s Non Compliance With SEC Subpoena Settled by Court


Cost of Proposed User Fees by Registered Investment Advisers Further Discussed

As most of our readers are aware, there has been a proposal advocated by various parties, including certain members of Congress, that a funding source to pay for the increase of SEC examinations over registered investment advisers be provided by imposing user fees on registered advisers. You probably wonder, if such proposals are placed into law, what the typical adviser would have to pay for its portion of the user fees.

According to a recent study authorized by Congress, the typical SEC examination of an investment adviser costs about $27,000 and the estimated annual cost for registered advisers for the user-fee funded examinations would be about $310 million. However, it is estimated that a majority of the 32,000 registered advisers may not have to pay any user fee due to the manner in which user-fees would be levied per registrant. It is assumed that the SEC would levy an annual user fee on those advisers with a higher than average amount of assets under management.

The study helps to put some numbers behind the costs of the increased number of examinations and possible user fee costs for the registrants. More information about the consultant’s study results may be found online.

SEC Valuation Guidance for All Funds

Tucked away in the SEC adopting release for the new money market rules is valuation guidance for all registered investment companies and business development companies (referred to herein as “funds”).

Use of Amortized Cost Valuation

Key Take Away: When a fund uses amortized cost valuation, the guidance requires the fund to actively monitor both market and issuer-specific developments that may indicate that the market-based fair value of a portfolio security has changed, resulting in the use of amortized cost valuation no longer being appropriate.

The SEC generally believes that a fund may only use the amortized cost method to value a portfolio security with a remaining maturity of 60 days or less when it can reasonably conclude, at each time it makes a valuation determination, that the amortized cost value of the portfolio security is approximately the same as the fair value of the security as determined without the use of amortized cost valuation. Existing credit, liquidity, or interest rate conditions in the relevant markets and issuer specific circumstances at each such time should be taken into account in making such an evaluation.

Accordingly, it would not be appropriate for a fund to use amortized cost to value a debt security with a remaining maturity of 60 days or less and thereafter not continue to review whether amortized cost continues to be approximately fair value until, for example, there is a significant change in interest rates or credit deterioration. Instead, the SEC believes the fund should evaluate the amortized cost each time it calculates its net asset value or otherwise values its portfolio securities.

A fund’s policies and procedures should be designed to ensure that the fund’s adviser is actively monitoring both market and issuer-specific developments that may indicate that the market-based fair value of a portfolio security has changed, and therefore the use of amortized cost valuation for that security may no longer be appropriate.

Other Valuation Matters

Key Take Away: When a fund holds securities that do not have readily available market quotations because they are not actively traded in the secondary markets, such securities are generally valued based upon “mark-to-model” or “matrix pricing” estimates.

In matrix pricing, portfolio asset values are derived from a range of different inputs, with varying weights attached to each input, such as pricing of new issues, yield curve information, spread information, and yields or prices of securities of comparable quality, coupon, maturity, and type. A fund might also consider evaluated prices from third-party pricing services, which may take into account these inputs as well as prices quoted from dealers that make markets in these instruments and financial models.

Fair Value for Thinly Traded Securities

Key Take Away: This portion of the guidance makes it clear that thinly traded securities need to be fair valued by taking into account market conditions existing at the time of valuation because the fair value of a security is the amount that a fund might reasonably expect to receive for the security upon its current sale. So, for example, a fund holding debt securities generally should not fair value these securities at par or amortized cost based on the expectation that the fund will hold those securities until maturity, if the fund could not reasonably expect to receive approximately that value upon the current sale of those securities under current market conditions.

The SEC acknowledged that matrix pricing and similar pricing methods involve estimates and judgments, which might introduce some “noise” into portfolio security prices, and therefore into a fund’s NAV per share when rounded to one basis point. However, the SEC continues to believe that market-based prices of portfolio securities provide meaningful information, and does not believe that amortized cost generally provides better or more accurate values of securities that do not frequently trade or that may or may not be held to maturity given a fund’s statutory obligation to investors to satisfy redemptions within seven days (and a fund’s disclosure commitment to generally satisfy redemptions much sooner).

The SEC has concerns about the use of the amortized cost method in valuing portfolio securities because its use may result in overvaluation or undervaluation in comparison to the actual markets. For this reason, there is a preference embodied in the Investment Company Act that funds value portfolio securities taking into account current market information. This ties to fair value for thinly traded securities because as a general principle, the fair value of a security is the amount that a fund might reasonably expect to receive for the security upon its current sale. So, fair value by its very nature requires taking into account market conditions existing at that time.

Use of Pricing Services

Key Take Away: This part of the guidance makes it clear that a board of directors needs to take special care when it approves the use of a pricing service because the board has a non-delegable responsibility to determine whether an evaluated price provided by a pricing service, or some other price, constitutes a fair value. So, in approving a pricing service, a board should consider, among other things, the following:

  • The inputs, methods, models, and assumptions used by the pricing service to determine its evaluated prices.
  • How the inputs, methods, models, and assumptions used by the pricing service are affected (if at all) as market conditions change.
  • The quality of the evaluated prices provided by the pricing service.
  • The extent to which the pricing service determines its evaluated prices as close as possible to the time as of which the fund calculates its net asset value.
  • Whether the board has a good faith basis for believing that the pricing service’s pricing methodologies produce evaluated prices that reflect what the fund could reasonably expect to obtain for the securities in a current sale under current market conditions.

As noted above, many funds use evaluated prices provided by third-party pricing services to assist them in determining the fair values of their portfolio securities. With regard to such pricing services, the SEC noted that the evaluated prices provided by pricing services are not, by themselves, readily available market quotations or fair values. So, reliance on a pricing service must be done with care.

Care must be taken because a fund’s board of directors has a non-delegable responsibility to determine whether an evaluated price provided by a pricing service, or some other price, constitutes a fair value for a fund’s portfolio security. In this regard, directors are required to satisfy themselves that all appropriate factors relevant to the value of securities for which market quotations are not readily available have been considered, and to continuously review the appropriateness of the method used in valuing each issue of security in a fund’s portfolio.

Update on Insider Trading in Mutual Fund Shares

As we reported in 2013, the U.S. Court of Appeals for the Seventh Circuit left open the possibility that insider trading prohibitions may apply to trading in mutual fund shares, and remanded the case to the district court to determine whether the insider’s alleged conduct properly fit under the misappropriation theory of insider trading. Now the district court has weighed in and declined to extend the misappropriation theory to the insider trading claim in the case because the theory was never raised with the court. (Securities and Exchange Commission v. Bauer, U.S. District Court, E.D. Wisconsin, Aug. 29, 2014) This result should allow mutual fund chief compliance officers to breathe a little sigh of relief.

The court noted in dismissing the allegations and counts that there is no authority to extend the misappropriation theory to a corporate insider trading mutual fund shares, and that it was not aware of any authority extending the misappropriation theory to a situation where the insider was a corporate insider at all times. Expressing further doubt about the application of insider trading theories to mutual funds, the court stated that no court has addressed whether insider trading theories apply to mutual fund redemptions, and that the SEC has never brought a claim under Section 10(b) in the mutual fund context.

Key Take Away: The SEC remains focused on insider trading.

While the SEC may not be inclined to bring another insider trading case related to trading in mutual fund shares in the near future, the SEC will not hesitate to bring an insider trading case related to trades by insiders related to portfolio securities. So, be extra vigilant in developing and adhering to insider trading policies.

Items like a fund freezing redemptions and selling off portfolio securities at discounted prices to generate cash are most likely material to investors, and care should be taken to disclose such material information to shareholders on a timely basis.


Failure to Disclose Conflict of Interest to Clients Results in SEC Enforcement Proceeding Against Registered Investment Adviser

The SEC has made it abundantly clear to registered investment advisers that failure to disclose conflicts of interest to clients will continue to be a basis for SEC enforcement action. A recent example is In the Matter of the Robare Group, Ltd., Mark L. Robare, and Jack L. Jones Jr. (Investment Advisers Act Release No 3907, Sept. 2, 2014). In this enforcement matter, the SEC alleges that the investment adviser failed to inform clients during the period of 2005 through 2011, that it was receiving compensation from a broker-dealer for client assets that were invested in certain mutual funds sponsored by the broker-dealer.

The Robare Group, Ltd., located in Houston, Texas reportedly has about 350 separately managed client accounts with about $150 million of assets under management. The advisory firm primarily services retail clients and utilizes the broker-dealer for, among other things, executive and custody services for its clients. A significant amount of client assets that are invested in mutual funds are invested, via discretionary authority by the adviser, in funds offered on the broker-dealer’s platform.

The SEC, in the complaint, alleges that the adviser and two of its limited partners, Messrs. Robare and Jones, violated the “anti-fraud” provisions under Sections 206(1) and (2) and 207 of the Advisers Act in failing to disclose the conflict of interests to the adviser’s clients. The SEC is asking the court to order the respondents to cease and desist from further violations of the anti-fraud provisions under the Advisers Act.

Adviser’s Non Compliance With SEC Subpoena Settled by Court

The SEC’s subpoena powers under the Investment Advisers Act of 1940 were recently affirmed by a court over the objections of the owner and operator of a SEC registered investment advisory firm (see SEC v. Stilwell, 2014 BL252718, S.D.N.Y., 1:14-mc-257 (ALC), 9/11/14).

The owner and operator of the advisory firm objected to the issuance of the SEC’s subpoena which required his testimony about, among other things, allegedly false statements made by his firm in connection with certain investment funds under its management. Because a member of the SEC’s staff told the owner that the SEC would be initiating enforcement proceedings in the matter, the owner objected to the subpoena because the SEC did not need his testimony and the subpoena served no “legitimate investigatory purpose.”

The SEC argued to the court that it had reached only “tentative conclusions” whether or not to proceed with enforcement proceedings against the advisory firm and needed additional evidence via the owner’s testimony to make a “final” enforcement decision. The court agreed with the SEC and ruled that the SEC showed that its subpoena was not issued for wrongful purposes. According to the court, the owner failed to refute the presumption that the subpoena was issued for appropriate purposes.

Although the SEC’s subpoena authority generally is unquestioned, it is likely, as a result of this matter where a U.S. court was required to weigh in on the SEC’s subpoena authority, there will be a directive sent out by the SEC to staff, to keep their comments to themselves as to whether enforcement proceedings will be brought prior to the completion of the SEC’s investigation and gathering of evidence.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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