Man Global Private Markets (Usa) Inc.

Allegations: ON APRIL 7, 2021, MAN GROUP PLC ("MAN"), AN ADVISORY AFFILIATE OF MAN GLOBAL PRIVATE MARKETS (USA) INC, BASED IN LONDON, U.K., AGREED TO PAY A FINE OF EURO 240,000 TO THE COMISION NACIONAL DEL MERCADO DE VALORES (THE "CNMV"), PURSUANT TO A SETTLED RESOLUTION, IN CONNECTION WITH THE CNMV'S FINDINGS THAT MAN HAD NOT COMPLIED WITH EUROPEAN UNION ("EU") REGULATIONS REQUIRING THE DISCLOSURE OF AN INVESTOR'S SHORT POSITIONS IN THE SECURITIES OF ANY ISSUER BASED IN AN EU MEMBER COUNTRY, SUCH AS SPAIN. SPECIFICALLY, THE EUROPEAN SECURITIES AND MARKETS AUTHORITY ("ESMA") HAS ISSUED REGULATIONS ON SHORT SELLING AND CREDIT DEFAULT SWAPS ("SSR") THAT REQUIRE INVESTORS TO FILE REPORTS DISCLOSING ANY SHORT POSITIONS ABOVE A THRESHOLD OF 0.2% OF AN ISSUER'S OUTSTANDING SHARES, WITH ADDITIONAL DISCLOSURE THRESHOLDS AT INCREASING INTERVALS OF 0.1%. THUS, AN INVESTOR MUST FILE DISCLOSURES CALCULATING ITS NET SHORT POSITION WHENEVER IT CROSSES THRESHOLDS (UP OR DOWN) OF 0.2%, 0.3%, 0.4%, 0.5% ETC. IN THE CASE OF MAN, THE CNMV DETERMINED THAT, BETWEEN DECEMBER 2017 AND NOVEMBER 2018, THREE OF MAN'S AFFILIATED MANAGERS HAD ON FIVE OCCASIONS FAILED TO CORRECTLY DISCLOSED THEIR NET SHORT POSITION IN FOUR SPANISH ISSUERS AMOUNTING TO BETWEEN 0.2% AND 0.7% OF THE ISSUERS' OUTSTANDING SHARES. THE SSR REGULATIONS IMPOSE RULES FOR CALCULATING NET SHORT POSITIONS AT THE FUND LEVEL AMONG AFFILIATED ENTITIES, WHICH MAN ATTEMPTED TO APPLY IN GOOD FAITH. SEE ESMA 70-145-408, QUESTION 8.5, AVAILABLE AT HTTPS://WWW.ESMA.EUROPA.EU/SITES/DEFAULT/FILES/LIBRARY/ESMA70-145-408_QA_ON_SSR.PDF. IN FOUR CASES, THE IRREGULARITIES AROSE FROM THE INCORRECT IDENTIFICATION OF THE POSITION HOLDING ENTITY WITHIN MAN; (FOR EXAMPLE, A POSITION HELD BY ONE MAN MANAGER WAS INCORRECTLY NOTIFIED AS A POSITION HELD BY ANOTHER MAN MANAGER). THIS MISREPORTING RESULTED IN DELAYED CORRECTING NOTIFICATIONS TO THE CNMV. IN ONE INSTANCE, A POSITION WAS INADVERTENTLY NOT REPORTED. THE ORDER RELATED TO MAN IS SET FORTH IN DISPATCH RECORD NO. 2021025805 OF THE CNMV. THE CNMV DID NOT DETERMINE THAT MAN ENGAGED IN ANY MISLEADING OR DECEPTIVE CONDUCT, NOR THAT IT COMMITTED ANY VIOLATION IN CONNECTION WITH PROVIDING INVESTMENT ADVISORY SERVICES TO ANY CLIENTS. Status: Final Sanction Detail: ON APRIL 7, 2021, MAN, AN ADVISORY AFFILIATE OF MAN GLOBAL PRIVATE MARKETS (USA) INC., AGREED TO PAY A FINE OF EURO 240,000 TO THE COMISION NACIONAL DEL MERCADO DE VALORES (THE "CNMV") IN CONNECTION WITH THE CNMV'S FINDINGS THAT MAN HAD NOT COMPLIED WITH EUROPEAN UNION ("EU") REGULATIONS REQUIRING THE DISCLOSURE OF AN INVESTOR'S SHORT POSITIONS IN THE SECURITIES OF ANY ISSUER BASED IN AN EU MEMBER COUNTRY, SUCH AS SPAIN. Summary: ON APRIL 7, 2021, MAN AGREED TO ACCEPT THE FINDINGS WITHOUT CONTESTING AND PAY A FINE OF EURO 240,000.