RegAlert2015-08-05
Added · Updated
SEC Division of Corporation Finance no-action letter: Guggenheim Partners Investment Management, LLC
Guggenheim Partners Investment Management, LLC requests a waiver of the disqualification from relying on Rule 506 of Regulation D under the Securities Act of 1933 resulting from an administrative order for violations of the Investment Advisers Act of 1940. The request cites that the violations involved fiduciary breaches and billing errors rather than securities offerings, and notes that GPIM has implemented substantial remedial measures, including restructuring compliance functions and retaining an independent consultant. GPIM agrees to provide written disclosure to investors regarding the Order until it submits a certification of compliance with the Order's undertakings to the Commission staff.
SEC published 7 documents in the last 30 days — get each new one by email the day it lands.
SIDi:ENYI
SIDLEY AUSTIN LLP
60 STATE STREET
34TH FLOOR
BOSTON , MA 02109
(617) 223 0300
(617) 223 0301 FAX emarino@sldley.com
(617) 223 0362
By Email and Overnight Courier
Chief, Office of Small Business Policy
Division of Corporation Finance
Securities and Exchange Commission
1 00 F Street, N .E.
Washington, DC 20549
BEIJING HONG KONG SHANGHAI
BOSTON HOUSTON SINGAPORE
BRUSSELS LONDON SYDNEY
CENTURY CITY LOS ANGELES TOKYO
CHICAGO NEW YORK WASHINGTON, D.C.
DALLAS PALO ALTO
GENEVA SAN FRANCISCO
FOUNDED 1866
Re: In the Matter of Guggenheim Partners Investment Management, LLC, Administrative Proceeding No. 3-16735 (August 10, 2015) Dear Mr. Gomez Abero:
We are writing on behalf of Guggenheim Partners lnyestment Management, LLC ("GPIM") in connection with the anticipated settlement with the Securities and Exchange Commission ("SEC" or "Commission") relating to In the Matter of Guggenheim Partners Investment Management, LLC. The settlement would result in an Order Instituting Administrative and Cease-and-Desist Proceedings Pursuant to Sections 203(e) and 203(k) of the Investment Advisers Act of 1940, Making Findings, and Imposing Remedial Sanctions and a Cease-and-Desist Order (the "Order") against GPIM. On behalf GPIM, we hereby respectfully request a waiver of any disqualification that will arise pursuant to Rule 506 of Regulation D under the Securities Act of 1933 (the "Securities Act") with respect to GPIM or any of its affiliates as a result ofthe entry of the Order. BACKGROUND GPIM has engaged in settlement discussions with the Division of Enforcement in connection with the above-captioned administrative proceeding. As a result of these discussions, GPIM has submitted an Offer of Settlement that will agree to the Order, which will be presented by the staff to the Commission. Sidley Austin (NY) LLP is a Delaware limited liability partnership doing business as Sidley Austin LLP and pradicing in affiliation YJith other Sidley Austin partnerships.
Read the rest free, and get an email when SEC publishes again
Lineage: In force
Source: Securities and Exchange Commission — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
More like this from SEC
SEC published 7 documents in the last 30 days. We email you each new one the day it's published.