Marco Investment Management Llc

Allegations: IN MARCH 2016, MIM AND STEVEN MARCO ENTERED INTO A SETTLEMENT WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION (THE "SEC") TO RESOLVE CERTAIN ASPECTS OF MIM'S OPERATIONS THAT THE SEC ALLEGED VIOLATED THE INVESTMENT ADVISERS ACT OF 1940 AND TWO RELATED RULES WITH RESPECT TO RECORDKEEPING, CALCULATION OF ASSETS UNDER MANAGEMENT, AND THE ADEQUACY OF COMPLIANCE POLICIES AND PROCEDURES. PRIMARILY, THE SETTLEMENT CONCERNED THE MANNER IN WHICH MIM CALCULATED MANAGEMENT FEES FOR CERTAIN CLIENTS. MIM CONTACTED EACH AFFECTED CLIENT AND REFUNDED ANY FEES THE SEC ALLEGED TO BE EXCESSIVE, WITHOUT REGARD TO ANY UNDERBILLINGS TO THE SAME CLIENT. IN ADDITION, FOR A PERIOD OF THREE YEARS, MR. MARCO WAS NOT PERMITTED TO SERVE AS CHIEF COMPLIANCE OFFICER OR COMPLIANCE OFFICER FOR ANY BROKER, DEALER, INVESTMENT ADVISER, MUNICIPAL SECURITIES DEALER, MUNICIPAL ADVISOR, TRANSFER AGENT, OR NATIONALLY RECOGNIZED STATISTICAL RATING ORGANIZATION. THE ORDER INSTITUTING PROCEEDINGS, WHICH SETS FORTH THE SEC'S ALLEGATIONS AS WELL AS THE ADMINISTRATIVE AND MONETARY SANCTIONS IMPOSED, CAN BE FOUND AT HTTPS://WWW.SEC.GOV/LITIGATION/ADMIN/2016/IA-4348.PDF. MIM AND MR. MARCO NEITHER ADMITTED NOR DENIED ITS ALLEGATIONS. Status: Final Sanction Detail: DISGORGEMENT: $124,750.44 PREJUDGMENT INTEREST: $7,595.94 REGISTRANT FINE: $100,000 - PAID MARCH 8, 2016 ADVISORY AFFILIATE FINE: $50,000 - PAID MARCH 8, 2016 Summary: AS DESCRIBED ABOVE, IN MARCH 2016, MIM AND STEVEN MARCO ENTERED INTO A SETTLEMENT WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION (THE "SEC") TO RESOLVE CERTAIN ASPECTS OF MIM'S OPERATIONS THAT THE SEC ALLEGED VIOLATED THE INVESTMENT ADVISERS ACT OF 1940 AND TWO RELATED RULES WITH RESPECT TO RECORDKEEPING, CALCULATION OF ASSETS UNDER MANAGEMENT, AND THE ADEQUACY OF COMPLIANCE POLICIES AND PROCEDURES. PRIMARILY, THE SETTLEMENT CONCERNED THE MANNER IN WHICH MIM CALCULATED MANAGEMENT FEES FOR CERTAIN CLIENTS. MIM CONTACTED EACH AFFECTED CLIENT AND REFUNDED ANY FEES THE SEC ALLEGED TO BE EXCESSIVE, WITHOUT REGARD TO ANY UNDERBILLINGS TO THE SAME CLIENT. IN ADDITION, FOR A PERIOD OF THREE YEARS, MR. MARCO WAS NOT PERMITTED TO SERVE AS CHIEF COMPLIANCE OFFICER OR COMPLIANCE OFFICER FOR ANY BROKER, DEALER, INVESTMENT ADVISER, MUNICIPAL SECURITIES DEALER, MUNICIPAL ADVISOR, TRANSFER AGENT, OR NATIONALLY RECOGNIZED STATISTICAL RATING ORGANIZATION. THE ORDER INSTITUTING PROCEEDINGS, WHICH SETS FORTH THE SEC'S ALLEGATIONS AS WELL AS THE ADMINISTRATIVE AND MONETARY SANCTIONS IMPOSED, CAN BE FOUND AT HTTPS://WWW.SEC.GOV/LITIGATION/ADMIN/2016/IA-4348.PDF. MIM AND MR. MARCO NEITHER ADMITTED NOR DENIED ITS ALLEGATIONS.