Action against Respondent, a statutory trust, in connection with alleged violations of the Investment Company Act relating to the pricing and administration of an affiliated unregistered money market fund.  According to the SEC, Respondent used a flawed methodology to determine the net asset value (“NAV”) of its shares, and used a stable NAV for some funds while using a floating NAV for others.  The SEC alleges that Respondent’s conduct was inconsistent with Rule 2a-7, disqualifying it from Rule 12d1-1 exemptions.  Respondent has agreed to pay a civil penalty of $225,000.

SEC Order