Advisers That Fail to Diligently Challenge Pricing Service Marks May Draw SEC Scrutiny

Advisers often use pricing services to value securities that do not have readily available market quotations. The SEC’s recent enforcement action against an investment adviser is a reminder that advisers must be vigilant when considering the appropriateness of pricing service marks. In this case, the adviser allegedly used pricing service marks for round lots when calculating its fund’s net asset value (NAV), even though it knew that round lot prices were typically higher than odd lot prices. The SEC claimed that, among other things, the adviser lacked appropriate compliance policies and procedures, sold shares at other than NAV and made materially misleading disclosures to investors about fund performance. This article outlines the adviser’s alleged violations and the terms of the SEC settlement order. For a similar action, see “SEC Settlement With PIMCO Highlights the Importance of Proper Valuation and Performance Disclosures” (Dec. 8, 2016).

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