United States: SEC Charges Investment Adviser for Inadequate Policies and Procedures Regarding Valuation of Private Fund Assets
By Todd Gibson, Annabelle North, and Aster Cheng
On 24 May 2023, the US Securities and Exchange Commission (SEC) announced the settlement of charges against Sciens Investment Management, LLC and Sciens Diversified Managers, LLC (collectively, Sciens) related to the valuation of certain private fund portfolio investments (Order). The SEC cited the often-used violations of Section 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-7, finding that Sciens failed to implement adequate policies and procedures to properly value certain private fund investments.
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