SEC v. Eric David Wanger and Wanger Investment Management, Inc. (marking the close, 2017)

Settled

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In July 2017 the SEC denied Eric David Wanger's application for consent to re-enter the securities industry, which had been barred in 2012 under a settled order finding he and his firm marked the close in at least 14 month-end or quarter-end trades to inflate a fund's reported performance. The 2012 order carried a $75,000 penalty for Wanger. The matter was not dismissed; the 2017 order leaves the bar in place.

The record

What was ordered

Civil penalty

$75k

Disgorgement

—

Prejudgment interest

—

Total relief

$75k

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 this Order Denying Application for Consent to Associate on July 10, 2017 in administrative proceeding 3-14676. The respondents on the underlying case are Eric David Wanger and Wanger Investment Management, Inc. (1 individual, 1 entity); the 2017 order itself concerns only Wanger. An earlier version of this record showed the matter as dismissed, which was wrong.

The proceeding began in December 2011. The Division alleged, and the Commission's settled order of July 2, 2012 found, that Wanger and his firm willfully violated the antifraud provisions by marking the closing price of stocks held by a fund they managed, in at least 14 month-end or quarter-end trades he executed personally away from the fund's usual broker, to inflate its reported performance. The 2012 order also found improper principal transactions with the fund and late Form 4 filings. Without admitting or denying the findings, Wanger agreed to a $75,000 penalty and a bar from the industry with a right to reapply after one year, and the firm to roughly $2,400 of disgorgement and interest and a censure.

Wanger then applied for consent to associate with a firm or start his own. The Commission found he had not shown the proposed association would be in the public interest and denied the application. The $75,000 penalty is Wanger's; it was imposed in 2012.

For the regulator's own account of the facts, read the primary document linked above.

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.

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

Timeline

1. 2017-07-10 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.

• 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 10, 2026. submit a correction.