Perella Weinberg Partners Capital Management Lp

Allegations: PERELLA WEINBERG PARTNERS LP ("PWPLP") AND TUDOR, PICKERING, HOLT & CO. SECURITIES LLC ("TPHS") CONSENTED TO THE ENTRY OF FINDINGS PERTAINING TO VIOLATIONS OF SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-4(B)(4) THEREUNDER FOR FAILURE TO MAINTAIN OR PRESERVE CERTAIN OFF-CHANNEL COMMUNICATIONS RELATED TO THEIR BUSINESSES. PERELLA WEINBERG PARTNERS CAPITAL MANAGEMENT LP ("PWPCM") CONSENTED TO THE ENTRY OF FINDINGS PERTAINING TO VIOLATIONS OF SECTIONS 204 OF THE INVESTMENT ADVISERS ACT OF 1940 AND RULE 204-2(A)(7) FOR FAILURE TO MAINTAIN OR PRESERVE CERTAIN OFF-CHANNEL COMMUNICATIONS RELATED TO RECOMMENDATIONS MADE, OR PROPOSED TO BE MADE, AND ADVICE GIVEN, OR PROPOSED TO BE GIVEN, TO CLIENTS. PWPLP, TPHS, AND PWPCM ALSO CONSENTED TO THE ENTRY OF FINDINGS FOR FAILURE TO REASONABLY SUPERVISE EMPLOYEES WITH A VIEW TO PREVENTING OR DETECTING VIOLATIONS OF SECTION 17(A) OF THE SECURITIES AND EXCHANGE ACT OF 1934 AND RULE 17A-4(B)(4) THEREUNDER OR SECTIONS 204 OF THE INVESTMENT ADVISERS ACT OF 1940 AND RULE 204-2(A)(7) THEREUNDER. Status: Final Sanction Detail: PWPLP, TPHS, AND PWPCM PAID THE $2,500,000 FINE FOR WHICH THEY WERE JOINTLY AND SEVERALLY LIABLE FOR ON OCTOBER 3, 2023; $1,250,000 OF THE TOTAL FINE WAS PAID BY THE ADVISER, AND THE REMAINING $1,250,000 WAS PAID COLLECTIVELY BY PWPLP AND TPHS. PWPLP AND TPHS WERE ALSO ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A) OF THE SECURITIES AND EXCHANGE ACT OF 1934 AND RULE 17A-4 THEREUNDER AND PWPCM WAS ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 204 OF THE INVESTMENT ADVISORS ACT OF 1940 AND RULE 204-2 THEREUNDER. Summary: THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS FOR THE SOLE PURPOSE OF SETTLING THIS DISCIPLINARY PROCEEDING, WITHOUT ADJUDICATION OF ANY ISSUES OF LAW OR FACT.