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SEC v. Guggenheim Partners Investment Management, LLC (2015)

Settled

Checked against the primary document on October 2, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, with sampled and disputed records read a second time. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.

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In August 2015 the SEC settled with Guggenheim Partners Investment Management over an undisclosed conflict of interest, after a senior executive took a $50 million loan from an advisory client, plus a billing error and compliance failures. Guggenheim paid a $20 million civil penalty.

The record

Structured fields for this action, as recorded in our case library.
Agency SEC
Release number 3-16735
Date filed 2015-08-10
Date resolved 2015-08-10
Status settled
Criminal parallel No
Defendants Guggenheim Partners Investment Management, LLC (entity)
Cited as charged or alleged Advisers Act s.204A ; Advisers Act s.206 (statutes and rules cited in the document; not a finding that they were violated)
Techniques

What was ordered

Civil penalty
$20m
Disgorgement
—
Prejudgment interest
—
Total relief
$20m
Alleged gain
—

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

What is alleged to have happened

The Securities and Exchange Commission issued the order on August 10, 2015.

The order finds that GPIM breached its fiduciary duty by not disclosing that a senior executive had borrowed $50 million from an advisory client to take part in an acquisition by its parent, then invested other clients in transactions alongside that client on different terms. It also finds GPIM billed a client management fees on non-managed assets and did not enforce parts of its compliance policies and code of ethics.

The references to insider trading are to the firm's code of ethics; no insider trading is alleged and the tag has been removed.

For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the release.

Timeline

  1. 2015-08-10 Administrative proceeding instituted (cease-and-desist)

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

The linked release is a work of the United States government and is not subject to copyright. Our summary and narrative above are our own writing.

Record added September 10, 2026. submit a correction.