Townsend Holdings Llc

Allegations: THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ENTERED AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS (THE "ORDER") AGAINST AON INVESTMENTS USA INC. ("AON"). THE ORDER ALLEGED THAT AON: (I)FAILED TO "ADEQUATELY INVESTIGATE" A CLIENT'S CONCERNS ABOUT DISCREPANCIES BETWEEN HISTORICAL RETURNS ANDRETURNS USED TO CALCULATE A "RISK SHARE RETURN RATE" USED TO DETERMINE EMPLOYEE CONTRIBUTIONS TOPENSIONS; (II) MADE "MATERIAL MISSTATEMENTS AND OMISSIONS" TO THE CLIENT ABOUT THE REASONS FOR REPORTINGDISCREPANCIES, AND (III) IDENTIFIED REPORTING ERRORS BUT DID NOT FULLY INVESTIGATE AND DISCLOSE THE IMPACT OFTHE ERRORS. AON CONSENTED TO THE SEC ORDER WITHOUT ADMITTING OR DENYING THE FINDINGS THEREIN. Status: Final Sanction Detail: IF SUSPENDED, ENJOINED OR BARRED, PROVIDE DURATION INCLUDING START DATE AND CAPACITIES AFFECTED (GENERAL SECURITIES PRINCIPAL, FINANCIAL OPERATIONS PRINCIPAL, ETC.). IF REQUALIFICATION BY EXAM/RETRAINING WAS A CONDITION OF THE SANCTION, PROVIDE LENGTH OF TIME GIVEN TO REQUALIFY/RETRAIN, TYPE OF EXAM REQUIRED AND WHETHER CONDITION HAS BEEN SATISFIED. IF DISPOSITION RESULTED IN A FINE, PENALTY, RESTITUTION, DISGORGEMENT OR MONETARY COMPENSATION, PROVIDE TOTAL AMOUNT, PORTION LEVIED AGAINST YOU OR AN ADVISORY AFFILIATE , DATE PAID AND IF ANY PORTION OF PENALTY WAS WAIVED: AON WAS ORDERED TO PAY A CIVIL MONETARY PENALTY OF $1,000,000.00, AND TO PAY DISGORGEMENT AND PRE-JUDGMENT INTEREST OF $542,187.79. AON PAID $1,542,187.79 TO THE SEC ON FEBRUARY 1, 2024. Summary: ON JANUARY 25, 2024, THE SEC INITIATED A SETTLED ADMINISTRATIVE PROCEEDING AGAINST AON. AON NEITHER ADMITTEDNOR DENIED THE SEC'S FINDINGS. THE ORDER ALLEGED THAT AON: (I) FAILED TO "ADEQUATELY INVESTIGATE" A CLIENT'SCONCERNS ABOUT DISCREPANCIES BETWEEN HISTORICAL RETURNS AND RETURNS USED TO CALCULATE A "RISK SHARERETURN RATE" USED TO DETERMINE EMPLOYEE CONTRIBUTIONS TO PENSIONS; (II) MADE "MATERIAL MISSTATEMENTS ANDOMISSIONS" TO THE CLIENT ABOUT THE REASONS FOR REPORTING DISCREPANCIES, AND (III) IDENTIFIED REPORTINGERRORS BUT DID NOT FULLY INVESTIGATE AND DISCLOSE THE IMPACT OF THE ERRORS. AS A RESULT, THE SEC ALLEGED THATAON VIOLATED SECTION 206(2) OF THE ADVISERS ACT. THE SEC ORDERED AON TO CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF THE REFERENCED SECTION, IMPOSED A CENSURE, REQUIREDDISGORGEMENT AND PRE-JUDGMENT INTEREST OF $542,187.79, AND IMPOSED A CIVIL MONETARY PENALTY OF $1,000,000.00.AS PART OF THE RESOLUTION OF THIS MATTER, THE SEC RECOGNIZED REMEDIAL EFFORTS AND AON'S COOPERATION.