P. Schoenfeld Asset Management Lp

Allegations: ON AUGUST 14, 2024, PSAM ENTERED INTO A SETTLEMENT WITH THE SEC AND CONSENTED TO THE ENTRY OF AN ORDER FINDING THAT FROM OCTOBER 18, 2018 THROUGH DECEMBER 21, 2021 PSAM VIOLATED SECTION 204 OF THE ADVISERS ACT AND RULE 204-2(A)(7) THEREUNDER BY FAILING TO MAINTAIN OR PRESERVE CERTAIN OFF-CHANNEL COMMUNICATIONS. THE ORDER FURTHER FOUND THAT PSAM FAILED TO IMPLEMENT A SYSTEM OF MONITORING REASONABLY EXPECTED TO DETERMINE WHETHER PERSONNEL WERE FOLLOWING ITS POLICIES AND PROCEDURES THAT PROHIBIT OFF-CHANNEL COMMUNICATIONS WHICH LED TO ITS FAILURE TO REASONABLY SUPERVISE ITS PERSONNEL WITHIN THE MEANING OF SECTION 203(E)(6) OF THE ADVISERS ACT. THE ORDER STATED THAT THE SEC CONSIDERED PSAM'S COOPERATION WITH THE SEC STAFF IN THE INVESTIGATION AND THE REMEDIAL STEPS PSAM HAD UNDERTAKEN, INCLUDING THE INITIATION OF IMPLEMENTATION OF TECHNOLOGICAL IMPROVEMENTS TO ENHANCE THE FIRM'S CAPABILITY TO PRESERVE ITS EMPLOYEES' ELECTRONIC COMMUNICATIONS, THE RETENTION AND CONTINUED USE OF A COMPLIANCE CONSULTANT TASKED WITH REMEDIATING ITS RECORDKEEPING DEFICIENCIES, AND THE CONDUCTING OF ONGOING MONITORING FOR POTENTIAL NON-COMPLIANCE WITH FIRM POLICIES. THE ORDER REQUIRED PSAM TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 204 OF THE ADVISERS ACT AND RULE 204-2 THEREUNDER, CENSURED PSAM, AND REQUIRED PSAM TO PAY A CIVIL MONETARY PENALTY OF $1,250,000. NO PORTION OF THE PENALTY WILL BE BORNE BY PSAM'S CLIENTS. Status: Final Sanction Detail: PSAM PAID A CIVIL MONETARY PENALTY IN THE AMOUNT OF $1,250,000 ON AUGUST 26, 2024. Summary: ON AUGUST 14, 2024, PSAM ENTERED INTO A SETTLEMENT WITH THE SEC AND CONSENTED TO THE ENTRY OF AN ORDER FINDING THAT FROM OCTOBER 18, 2018 THROUGH DECEMBER 21, 2021 PSAM VIOLATED SECTION 204 OF THE ADVISERS ACT AND RULE 204-2(A)(7) THEREUNDER BY FAILING TO MAINTAIN OR PRESERVE CERTAIN OFF-CHANNEL COMMUNICATIONS. THE ORDER FURTHER FOUND THAT PSAM FAILED TO IMPLEMENT A SYSTEM OF MONITORING REASONABLY EXPECTED TO DETERMINE WHETHER PERSONNEL WERE FOLLOWING ITS POLICIES AND PROCEDURES THAT PROHIBIT OFF-CHANNEL COMMUNICATIONS WHICH LED TO ITS FAILURE TO REASONABLY SUPERVISE ITS PERSONNEL WITHIN THE MEANING OF SECTION 203(E)(6) OF THE ADVISERS ACT. THE ORDER STATED THAT THE SEC CONSIDERED PSAM'S COOPERATION WITH THE SEC STAFF IN THE INVESTIGATION AND THE REMEDIAL STEPS PSAM HAD UNDERTAKEN, INCLUDING THE INITIATION OF IMPLEMENTATION OF TECHNOLOGICAL IMPROVEMENTS TO ENHANCE THE FIRM'S CAPABILITY TO PRESERVE ITS EMPLOYEES' ELECTRONIC COMMUNICATIONS, THE RETENTION AND CONTINUED USE OF A COMPLIANCE CONSULTANT TASKED WITH REMEDIATING ITS RECORDKEEPING DEFICIENCIES, AND THE CONDUCTING OF ONGOING MONITORING FOR POTENTIAL NON-COMPLIANCE WITH FIRM POLICIES. THE ORDER REQUIRED PSAM TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 204 OF THE ADVISERS ACT AND RULE 204-2 THEREUNDER, CENSURED PSAM, AND REQUIRED PSAM TO PAY A CIVIL MONETARY PENALTY OF $1,250,000. NO PORTION OF THE PENALTY WILL BE BORNE BY PSAM'S CLIENTS.