SEC v. Semper Capital Management, L.P. (mismarking, 2020)

Settled

✓ Checked against the primary document on October 3, 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 2020, the Securities and Exchange Commission settled an action with Semper Capital Management, L.P., alleging conduct this library classifies as mismarking. The release records a civil penalty of $375,000, disgorgement of $103,228, prejudgment interest of $25,000.

The record

What was ordered

Civil penalty

$375k

Disgorgement

$103k

Prejudgment interest

$25k

Total relief

$503k

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 announced this matter on April 28, 2020 as release 3-19773. The respondents named are Semper Capital Management, L.P. (0 individuals, 1 entity).

This library tags the matter as mismarking, based on the conduct the regulator describes. Each tag links to a page explaining how that technique works, what statute it engages, and what penalties comparable actions have attracted. The tagging is ours, not the regulator's: agencies charge statutory provisions, not technique names.

The relief recorded in our data is a civil monetary penalty of $375,000, disgorgement of $103,228, prejudgment interest of $25,000. Penalty and disgorgement are distinct: disgorgement returns the gain, while the penalty is punitive. We store them separately so that aggregate figures across the library are not double-counted.

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.

What technique is this, and how does it work?

This action is tagged with one technique in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.

• Mismarking — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2020-04-28 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.

• SEC order

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.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added September 20, 2026. submit a correction.