Ratan Capital Management, Lp

Allegations: THE SEC ALLEGED THAT RATAN AND MS. CHOPRA WILLFULLY VIOLATED CERTAIN SECTIONS OF THE SECTIONS OF THE INVESTMENT ADVISERS ACT OF 1940, SPECIFICALLY VIOLATED SECTION 207 OF THE INVESTMENT ADVISERS ACT OF 1940 (THE "ADVISERS ACT"), AND SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-8 THEREUNDER.THEREUNDER. Status: Final Sanction Detail: $200,000 FOR NEHAL CHOPRA AND $200,000 FOR RATAN. PAID IN DECEMBER 2017. Summary: ON DECEMBER 5, 2017, THE SEC ENTERED INTO A SETTLEMENT ORDER WITH RATAN AND ITS MANAGING PARTNER, NEHAL CHOPRA, AMONG OTHERS, SETTLING AN ADMINISTRATIVE ACTION. THE SEC FOUND THAT FROM 2013 TO 2014, RATAN AND MS. CHOPRA FAILED TO DISCLOSE THAT MS. CHOPRA'S SPOUSE PROVIDED CERTAIN INVESTMENT AND OPERATIONAL SERVICES TO RATAN. MS. CHOPRA'S SPOUSE SERVED AS A CONSULTANT INVESTMENT ANALYST TO RATAN AND MADE INVESTMENT RECOMMENDATIONS TO RATAN AND MS. CHOPRA WHILE HE WAS EMPLOYED BY ANOTHER INVESTMENT ADVISER UTILIZING A SIMILAR INVESTMENT STRATEGY. THE SEC FOUND THAT MS. CHOPRA'S SPOUSE SHARED RESEARCH AND CONFIDENTIAL INFORMATION OBTAINED THROUGH HIS EMPLOYMENT AT THE OTHER INVESTMENT ADVISER WITH MS. CHOPRA AND RATAN. THE SEC FURTHER FOUND THAT RATAN AND MS. CHOPRA WILLFULLY VIOLATED SECTION 207 OF THE ADVISERS ACT, AND SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-8 THEREUNDER DUE TO THE FAILURE TO DISCLOSE MS. CHOPRA'S HUSBAND'S ROLE WITH RATAN. RATAN AND MS. CHOPRA CONSENTED, WITHOUT ADMITTING OR DENYING THE FINDINGS, TO CEASE AND DESIST FROM COMMITTING OR CAUSING FUTURE VIOLATIONS OF SECTIONS 207 AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-8 THEREUNDER, AND TO PAY A CIVIL PENALTY OF $200,000 EACH.