15 Equity, Llc

Allegations: ON DECEMBER 23, 2013, THE SECURITIES AND EXCHANGE COMMISSION ENTERED AN ADMINISTRATIVE ORDER AGAINST WEST COAST ASSET MANAGEMENT, INC. ("WCAM") AND LANCE W. HELFERT, THE PRESIDENT AND DIRECTOR OF WCAM. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS THEREIN, WCAM AND MR. HELFERT CONSENTED TO THE ENTRY OF THE ORDER. THE MATTER INVOLVED STATEMENTS BY WCAM AND HELFRT IN AN EMAIL TO AN ADVISORY CLIENT IN NOVEMBER 2008 REGARDING A HEDGE FUND WCAM MANAGED, THE WEST COAST OPPORTUNITY FUND ("WCOF"). IN RESPONSE TO A QUESTION FROM A CLIENT'S REPRESENTATIVE WHO WAS CONSIDERING AN ADIDTIONAL INVESMENT IN WCOF, MR. HELFERT STATED THAT THERE HAD BEEN ONLY TWO MINOR REDEPMTIONS FROM WCOF, AND THAT THERE HAD BEEN NET INFLOWS INTO THE FUND. WCAM AND MR. HELFRT CONSENTED TO VIOLATIONS OF THE SECTION 17(A)(2) OF THE SECURITITES ACT, SECTIONS 206(2) AND 206(4) OF HE ADVISERS ACT AND RULE 206(4)-8(A)(1), EACH OF WHICH REQUIRES ONLY A SHOWING OF NEGLIGENCE. Status: Final Sanction Detail: MR. HELFERT PAID THE FINE IN THE AMOUNT OF $32,500 ON 1/3/2014. Summary: UNDER THE TERMS OF THE ORDER, WCAM ALSO AGREED TO PAY A PENALTY OF $100,000, A DISGORGEMENT OF $51,113 AND PREJUDGEMENT INTEREST OF $5,073 TO THE SECURITIES AND EXCHANGE COMMISSION. MR. HELFERT AGREED TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $32,500.