Wilshire Advisors Llc

Allegations: ON OCTOBER 12, 2015, DE NEDERLANDSCHE BANK N.V. ("DNB") IMPOSED A 25,000 EURO ADMINISTRATIVE FINE ON WILSHIRE ASSOCIATES EUROPE B.V. ("WILSHIRE EUROPE") FOR VIOLATING ARTICLE 3:72, PARAGRAPH ONE, OF THE FINANCIAL SUPERVISION ACT FOR FAILURE TO SUBMIT WITHIN THE REQUIRED TIME PERIOD ITS QUARTERLY REPORT FOR INVESTMENT FIRMS FOR THE SECOND QUARTER OF 2015. WILSHIRE EUROPE DID NOT VIOLATE ANY OTHER PROVISIONS OF THE FINANCIAL SUPERVISION ACT IN CONNECTION WITH THIS DECISION. Status: Final Sanction Detail: PURSUANT TO THE DECISION, DNB IMPOSED AN ADMINISTRATIVE FINE OF 25,000 EUROS TO BE PAID WITHIN SIX WEEKS OF THE RESOLUTION DATE. NO PORTION OF THE PENALTY WAS WAIVED. THE ADMINISTRATIVE FINE WAS PAID ON NOVEMBER 6, 2015. Summary: THE DECISION WAS FINAL AND NO FURTHER ACTION WAS TAKEN BY DNB UPON PAYMENT OF THE ADMINISTRATIVE FINE BY WILSHIRE EUROPE.

Allegations: ON NOVEMBER 18, 2019, DE NEDERLANDSCHE BANK N.V. ("DNB") IMPOSED A 31,875 EURO ADMINISTRATIVE FINE ON WILSHIRE ASSOCIATES EUROPE B.V. ("WILSHIRE EUROPE") FOR VIOLATING ARTICLE 3:72, PARAGRAPH ONE, OF THE FINANCIAL SUPERVISION ACT FOR FAILURE TO SUBMIT WITHIN THE REQUIRED TIME PERIOD ITS QUARTERLY REPORT FOR INVESTMENT FIRMS FOR THE FOURTH QUARTER OF 2018. WILSHIRE EUROPE DID NOT VIOLATE ANY OTHER PROVISIONS OF THE FINANCIAL SUPERVISION ACT IN CONNECTION WITH THIS DECISION. Status: Final Sanction Detail: PURSUANT TO THE DECISION, DNB IMPOSED AN ADMINISTRATIVE FINE OF 31,875 EUROS TO BE PAID WITHIN SIX WEEKS OF RESOLUTION DATE. NO PORTION OF THE PENALTY WAS WAIVED. THE ADMINISTRATIVE FINE WAS PAID ON JANUARY 9, 2020. Summary: THE DECISION WAS FINAL AND NO FURTHER ACTION WAS TAKEN BY DNB UPON PAYMENT OF THE ADMINISTRATIVE FINE BY WILSHIRE EUROPE.

Allegations: ON JUNE 4, 2018, THE REGISTRANT ("LYXOR") ENTERED INTO A AGREEMENT WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ("SEC") TO SETTLE CHARGES RELATING TO A 2012 AGREEMENT LYXOR ENTERED INTO WITH THIRD-PARTY ADVISERS THAT MANAGED FUNDS IN WHICH LYXOR INVESTED CERTAIN CLIENT ASSETS. THAT AGREEMENT HAD A PROVISION FOR PAYMENTS TO BE MADE TO LYXOR BASED ON THE TOTAL AMOUNT OF CLIENT ASSETS PLACED OR MAINTAINED IN CERTAIN FUNDS MANAGED BY THE THIRD-PARTY ADVISERS, AND LYXOR SUBSEQUENTLY RECEIVED PAYMENT PURSUANT TO THE AGREEMENT. THE SEC ALLEGED LYXOR FAILED TO DISCLOSE THE CONFLICTS OF INTEREST ARISING FROM THE AGREEMENT; THE AGREEMENT WAS IN CONTRAVENTION OF INVESTMENT MANAGEMENT AGREEMENTS LYXOR HAD WITH TWO CLIENTS; LYXOR FAILED TO IMPLEMENT POLICIES AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT CONFLICTS OF INTEREST; AND LYXOR FAILED TO MAINTAIN ACCURATE BOOKS AND RECORDS TO REFLECT RECEIPT OF PAYMENT UNDER THE AGREEMENT. THE SEC FOUND, AND LYXOR NEITHER ADMITTED NOR DENIED, THAT LYXOR VIOLATED SECTION 206(2) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT"), SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER, AND SECTION 204(A) OF THE ADVISERS ACT AND RULE 204-2(A)(2) THEREUNDER. Status: Final Sanction Detail: PURSUANT TO THE SETTLEMENT, THE SEC ORDERED A CIVIL MONETARY PENALTY IN THE AMOUNT OF $500,000. THE PENALTY WILL BE PAID WITHIN 14 DAYS OF THE ENTRY OF THE ORDER. NO PORTION OF THE PENALTY WAS WAIVED. Summary: ON JUNE 4, 2018, THE SEC ANNOUNCED AN AGREEMENT WITH THE REGISTRANT TO SETTLE THE CHARGES RELATING TO THE 2012 AGREEMENT. THE SEC ADMINISTRATIVE ORDER IS FINAL. THE CIVIL MONETARY PENALTY WILL BE PAID WITHIN 14 DAYS OF THE ENTRY OF THE ORDER.