Nomura Investment Management Business Trust

Allegations: ON THE BASIS OF THE ORDER AND OFFERS OF SETTLEMENT BY DELAWARE MANAGEMENT COMPANY ("DMC") AND DELAWARE INVESTMENTS FUND ADVISERS ("DIFA"), THE COMMISSION FOUND THAT: 1) DMC AND DIFA SERVED OR ACTED AS AN INVESTMENT ADVISER OR SUB-ADVISER TO REGISTERED INVESTMENT COMPANIES ("FUND SERVICE ACTIVITIES") AS OF APRIL 1, 2015 AND, NOTWITHSTANDING THE ENTRY OF AN INJUNCTION AGAINST AN AFFILIATE OF DMC AND DIFA ON THAT DATE AND THE RESULTING STATUTORY DISQUALIFICATION OF DMC AND DIFA, CONTINUED TO ENGAGE IN FUND SERVICE ACTIVITIES AFTER APRIL 1, 2015 WITHOUT EXEMPTIVE RELIEF; 2) AS A RESULT OF THE ENTRY OF THE INJUNCTION AGAINST THE AFFILIATE, SECTIONS 9(A)(2) AND 9(A)(3) OF THE INVESTMENT COMPANY ACT TOGETHER ALSO PROHIBITED DMC AND DIFA FROM ENGAGING IN FUND SERVICE ACTIVITIES AS OF APRIL 1, 2015; 3) DMC AND DIFA DID NOT CONTACT THE COMMISSION STAFF TO BEING THE PROCESS OF OBTAINING EXEMPTIVE RELIEF UNTIL APRIL 7, 2015; AND 4) AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, EACH OF DMC AND DIFA VIOLATED SECTION 9(A) OF THE INVESTMENT COMPANY ACT. Status: Final Sanction Detail: REGISTRANT WAS ORDERED TO PAY A TOTAL FINE OF $40,000. Summary: IN JULY 2015, DELAWARE MANAGEMENT COMPANY ("DMC") AND DELAWARE INVESTMENTS FUND ADVISERS ("DIFA") ENTERED INTO A SETTLEMENT OF AN ADMINISTRATIVE PROCEEDING WITH THE US SEC. DMC AND DIFA ARE EACH A SERIES OF THE REGISTRANT THAT ADVISE OR SUB-ADVISE REGISTERED INVESTMENT COMPANIES ("FUND SERVICE ACTIVITIES"). THE US SEC'S ORDER FOUND THAT DMC AND DIFA VIOLATED SECTION 9(A) OF THE INVESTMENT COMPANY ACT DUE TO ENGAGING IN FUND SERVICE ACTIVITIES FROM APRIL 1, 2015 THROUGH MAY 15, 2015 WITHOUT EXEMPTIVE RELIEF. DUE TO AN INJUNCTION AGAINST AN AFFILIATE OF DMC AND DIFA ON APRIL 1, 2015, DMC AND DIFA REQUIRED EXEMPTIVE RELIEF UNDER SECTION 9 OF THE INVESTMENT COMPANY ACT TO CONTINUE TO BE ELIGIBLE TO PROVIDE FUND SERVICE ACTIVITIES AFTER APRIL 1, 2015. ON MAY 15, 2015, THE US SEC STAFF, ACTING UNDER DELEGATED AUTHORITY FROM THE US SEC, GRANTED TEMPORARY EXEMPTIVE RELIEF FROM SECTION 9(A) OF THE INVESTMENT COMPANY ACT WITH RESPECT TO THE INJUNCTION. ON JULY 6TH, 2015, THE US SEC ISSUED TEMPORARY EXEMPTIVE RELIEF AND A NOTICE OF APPLICATION FOR PERMANENT EXEMPTIVE RELIEF FROM SECTION 9(A) OF THE INVESTMENT COMPANY ACT WITH RESPECT TO THE INJUNCTION. ON AUGUST 3, 2015, THE SEC GRANTED TO DMC AND DIFA PERMANENT EXEMPTIVE RELIEF FROM THE PROVISIONS OF SECTION 9(A) INDICATING THAT THE SEC HAS DETERMINED THAT DMC AND DIFA HAVE MET THE STANDARD FOR RECEIVING EXEMPTIVE RELIEF. WITHOUT ADMITTING OR DENYING THE VALIDITY OF THE US SEC'S FINDINGS, DMC AND DIFA EACH AGREED TO PAY A PENALTY OF $20,000.

Allegations: THE ORDER ALLEGES THAT, BETWEEN JANUARY 1, 2017 AND APRIL 2021: (1) MIMBT VALUED CERTAIN COLLATERALIZED MORTGAGE-BACKED OBLIGATIONS ("CMOS") AT INFLATED PRICES; (2) MIMBT EXECUTED DEALER-INTERPOSED AND INTERNAL CROSS TRADES OF THOSE CMOS BETWEEN REGISTERED INVESTMENT COMPANY CLIENTS AND OTHER CLIENTS AT PRICES THAT DEVIATED FROM MARKET PRICES; (3) CERTAIN DISCLOSURES OF MIMBT RELATING TO PERFORMANCE, VALUATION, LIQUIDITY AND CROSS TRADING CONTAINED FALSE AND MISLEADING STATEMENTS AND OMISSIONS; AND (4) MIMBT FAILED TO IMPLEMENT POLICIES AND PROCEDURES RELATING TO VALUATION, CONFLICTS OF INTEREST AND CROSS TRADES. Status: Final Sanction Detail: REGISTRANT CONSENTED TO PAY (A) DISGORGEMENT OF $7,633,671 AND PREJUDGMENT INTEREST OF $2,197,535; AND (B) A CIVIL MONEY PENALTY IN THE AMOUNT OF $70,000,000. Summary: REGISTRANT HAS PAID DISGORGEMENT OF $7,633,671 AND PREJUDGMENT INTEREST OF $2,197,535 TO THE SEC ON 9/20/2024. REGISTRANT HAS PAID THE CIVIL MONEY PENALTY IN THE AMOUNT OF $70,000,000 TO THE SEC ON 9/20/2024. THE SEC MAY DISTRIBUTE THE CIVIL MONEY PENALTIES TO IMPACTED INVESTORS, IN ITS DISCRETION, IN A FAIR FUND DISTRIBUTION.