Advent Capital Management, Llc

Allegations: THIS REGULATORY ACTION IS RELATED TO TWO ALLEGED VIOLATIONS OF RULE 105 OF REGULATION M UNDER THE SECURITIES EXCHANGE ACT OF 1934. RULE 105 GENERALLY PROHIBITS BUYING AN EQUITY SECURITY IN AN UNDERWRITTEN SECONDARY PUBLIC OFFERING IF THE BUYER SOLD SHORT THE SAME SECURITY DURING THE RESTRICTED PERIOD SPECIFIED IN THE RULE (GENERALLY FIVE BUSINESS DAYS BEFORE THE PRICING OF THE OFFERING). THIS REGULATORY ACTION IS RELATED TO ADVENT CAPITAL MANAGEMENT, LLC'S PURCHASES OF SECURITIES, ON BEHALF OF ITS INVESTMENT FUND CLIENTS, IN CONNECTION WITH TWO SECONDARY PUBLIC OFFERINGS IN 2012. Status: Final Sanction Detail: THE SEC ORDERED ADVENT CAPITAL MANAGEMENT, LLC TO (1) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF RULE 105 OF REGULATION M OF THE SECURITIES EXCHANGE ACT OF 1934 AND (2) PAY DISGORGEMENT OF $75,292, PREJUDGMENT INTEREST OF $3,836.36, AND A CIVIL MONEY PENALTY IN THE AMOUNT OF $65,000 (FOR A TOTAL OF $144,128.36) TO THE UNITED STATES TREASURY. Summary: ON SEPTEMBER 16, 2014, ADVENT CAPITAL MANAGEMENT, LLC VOLUNTARILY AGREED, WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS, TO A SETTLEMENT WITH THE SEC RELATING TO RULE 105 OF REGULATION M UNDER THE SECURITIES AND EXCHANGE ACT OF 1934. ADVENT CAPITAL MANAGEMENT, LLC PAID DISGORGEMENT OF $75,292, PREJUDGMENT INTEREST OF $3,836.36, AND A CIVIL MONEY PENALTY IN THE AMOUNT OF $65,000 (FOR A TOTAL OF $144,128.36) TO THE UNITED STATES TREASURY ON OR ABOUT SEPTEMBER 16, 2014.