Action against Respondents, an investment adviser, two of its affiliated investment advisers, and its affiliated broker-dealer, in connection with their alleged use of faulty models to create mutual funds and investment strategies. According to the SEC, the models were developed solely by a junior analyst, contained errors, and did not work as promised. The SEC further alleges that, when Respondent adviser and one of its affiliate advisers learned of the errors, they stopped using the models without telling investors or disclosing the errors. Respondent adviser has agreed to pay disgorgement of $24,599,896, prejudgment interest of $3,682,195, and a civil penalty of $21,000,000. Respondent affiliate advisers have agreed to pay disgorgement of $15,000,000, prejudgment interest of $2,235,765, and a civil penalty of $21,000,000, and isgorgement of $1,700,000, prejudgment interest of $258,162, and a civil monetary penalty of $800,000, respectively. Respondent broker-dealer has agreed to pay disgorgement of $12,000,000, prejudgment interest of $1,826,022, and a civil penalty of $4,000,000.