Aon Advantage Funds 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. ("AIUSA"). THE ORDER ALLEGED THAT AIUSA: (I) FAILED TO "ADEQUATELY INVESTIGATE" A CLIENT'S CONCERNS ABOUT DISCREPANCIES BETWEEN HISTORICAL RETURNS AND RETURNS USED TO CALCULATE A "RISK SHARE RETURN RATE" USED TO DETERMINE EMPLOYEE CONTRIBUTIONS TO PENSIONS; (II) MADE "MATERIAL MISSTATEMENTS AND OMISSIONS" TO THE CLIENT ABOUT THE REASONS FOR REPORTING DISCREPANCIES, AND (III) IDENTIFIED REPORTING ERRORS BUT DID NOT FULLY INVESTIGATE AND DISCLOSE THE IMPACT OF THE ERRORS. AIUSA CONSENTED TO THE SEC ORDER WITHOUT ADMITTING OR DENYING THE FINDINGS THEREIN. Status: Final Sanction Detail: AIUSA 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. AIUSA 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 AIUSA. AIUSA NEITHER ADMITTED NOR DENIED THE SEC'S FINDINGS. THE ORDER ALLEGED THAT AIUSA: (I) FAILED TO "ADEQUATELY INVESTIGATE" A CLIENT'S CONCERNS ABOUT DISCREPANCIES BETWEEN HISTORICAL RETURNS AND RETURNS USED TO CALCULATE A "RISK SHARE RETURN RATE" USED TO DETERMINE EMPLOYEE CONTRIBUTIONS TO PENSIONS; (II) MADE "MATERIAL MISSTATEMENTS AND OMISSIONS" TO THE CLIENT ABOUT THE REASONS FOR REPORTING DISCREPANCIES, AND (III) IDENTIFIED REPORTING ERRORS BUT DID NOT FULLY INVESTIGATE AND DISCLOSE THE IMPACT OF THE ERRORS. AS A RESULT, THE SEC ALLEGED THAT AIUSA VIOLATED SECTION 206(2) OF THE ADVISERS ACT. THE SEC ORDERED AIUSA TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF THE REFERENCED SECTION, IMPOSED A CENSURE, REQUIRED DISGORGEMENT 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 AIUSA'S COOPERATION.