Wcas Management Corporation

Allegations: THE ORDER FOUND THAT WCAS DID NOT DISCLOSE CONFLICTS OF INTEREST BETWEEN WCAS AND ITS PRIVATE EQUITY FUND CLIENTS IN CONNECTION WITH AN AGREEMENT BETWEEN WCAS AND A GROUP PURCHASING ORGANIZATION THAT PROVIDED SERVICES TO CERTAIN PORTFOLIO COMPANIES OWNED BY FUNDS ADVISED BY WCAS. BY VIRTUE OF THIS CONDUCT, THE ORDER FOUND THAT WCAS VIOLATED SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-8 THEREUNDER. Status: Final Sanction Detail: PURSUANT TO THE ORDER, WCAS WAS CENSURED, ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-8 THEREUNDER, AND ORDERED TO PAY DISGORGEMENT IN THE AMOUNT OF $623,035 PLUS PREJUDGMENT INTEREST OF $65,784.78, AS WELL AS A CIVIL MONEY PENALTY IN THE AMOUNT OF $90,000. Summary: ON APRIL 24, 2018, WCAS, WITHOUT ADMITTING OR DENYING ANY FINDINGS EXCEPT AS TO THE COMMISSION'S JURISDICTION AND THE SUBJECT MATTER OF THE PROCEEDINGS, CONSENTED TO THE ENTRY OF AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE AND DESIST PROCEEDINGS (THE "ORDER") IN SETTLEMENT OF AN ADMINISTRATIVE PROCEEDING. THE ORDER FOUND THAT WCAS DID NOT DISCLOSE CONFLICTS OF INTEREST BETWEEN WCAS AND ITS PRIVATE EQUITY FUND CLIENTS IN CONNECTION WITH AN AGREEMENT BETWEEN WCAS AND A GROUP PURCHASING ORGANIZATION THAT PROVIDED SERVICES TO CERTAIN PORTFOLIO COMPANIES OWNED BY FUNDS ADVISED BY WCAS. BY VIRTUE OF THIS CONDUCT, THE ORDER FOUND THAT WCAS VIOLATED SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-8 THEREUNDER. PURSUANT TO THE ORDER, WCAS WAS CENSURED, ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-8 THEREUNDER, AND ORDERED TO PAY DISGORGEMENT IN THE AMOUNT OF $623,035 PLUS PREJUDGMENT INTEREST OF $65,784.78, AS WELL AS A CIVIL MONEY PENALTY IN THE AMOUNT OF $90,000. THE ORDER IS FINAL AND THE DISGORGEMENT, INTEREST, AND PENALTY WERE PAID IN FULL TO THE SEC ON MAY 2, 2018. NO WCAS INVESTOR, PARTNERSHIP OR PORTFOLIO COMPANY PAID ANY FEES OR EXPENSES UNDER THE GROUP PURCHASING AGREEMENT.

Allegations: WCAS DID NOT FILE A TIMELY AMENDMENT TO ITS SCHEDULE 13D DISCLOSURE AFTER IT SOLD SHARES IN HANGER, INC. AND DECIDED TO LIQUIDATE ITS POSITION. THE 2020 ORDER FOUND THAT WCAS VIOLATED SECTION 13(D)(2) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND RULE 13D-2(A) THEREUNDER Status: Final Sanction Detail: THE ORDER IS FINAL AND THE PENALTY WAS PAID IN FULL TO THE SEC ON SEPTEMBER 22, 2020. Summary: THE ORDER IS FINAL AND THE PENALTY WAS PAID IN FULL TO THE SEC ON SEPTEMBER 22, 2020.