Lime Rock Management Lp

Allegations: ON JANUARY 17, 2017, THE U.S. SECURITIES AND EXCHANGE COMMISSION (THE "SEC") INSTITUTED ADMINISTRATIVE PROCEEDINGS AGAINST THE REGISTRANT, PURSUANT TO SECTIONS 203(E) AND 203(K) OF THE ADVISERS ACT OF 1940, AS AMENDED (THE "ADVISERS ACT"), FINDING THAT THE REGISTRANT HAD VIOLATED ADVISERS ACT RULE 206(4)-5 WHEN AN EMPLOYEE MADE A $1,000 PERSONAL CONTRIBUTION TO THE CAMPAIGN OF A CANDIDATE FOR PRESIDENT OF THE UNITED STATES, AND THEN GOVERNOR OF OHIO, WHILE THE REGISTRANT ADVISED A POOLED INVESTMENT VEHICLE WHERE AN OHIO PUBLIC ENTITY WAS AN INVESTOR. THE SEC FOUND THAT AFTER THE CONTRIBUTION WAS MADE, ITS RETURN WAS SOUGHT AND RECEIVED, AND NOTED THAT ADVISERS ACT RULE 206(4)-5 DOES NOT REQUIRE A SHOWING OF QUID PRO QUO OR ACTUAL INTENT TO INFLUENCE AN ELECTED OFFICIAL OR CANDIDATE. Status: Final Sanction Detail: CIVIL MONETARY PENALTY OF $75,000. Summary: ON JANUARY 17, 2017, THE SEC INSTITUTED ADMINISTRATIVE PROCEEDINGS AGAINST THE REGISTRANT REGARDING A CAMPAIGN CONTRIBUTION BY AN EMPLOYEE OF THE REGISTRANT MADE IN VIOLATION OF THE SEC'S RULES GOVERNING POLITICAL CONTRIBUTIONS BY INVESTMENT ADVISER EMPLOYEES AND THE REGISTRANT'S OWN COMPLIANCE POLICIES. WITHOUT ADMITTING OR DENYING LIABILITY, THE REGISTRANT AGREED TO PAY $75,000 TO RESOLVE THE MATTER. UPON BECOMING AWARE OF THE $1,000 CONTRIBUTION, THE RESPONDENT CAUSED THE EMPLOYEE TO OBTAIN ITS RETURN AND VOLUNTARILY REPORTED THE MATTER TO THE SEC. THE ORDER SETTLING THIS MATTER FINDS THAT ADVISERS ACT RULE 206(4)-5 DOES NOT REQUIRE A SHOWING OF QUID PRO QUO OR ACTUAL INTENT TO INFLUENCE AN ELECTED OFFICIAL OR CANDIDATE FOR PUBLIC OFFICE, AND THAT THE SEC WAS NOT REQUIRED TO SHOW THAT THE REGISTRANT WAS AWARE OF THE ACTIONS RESULTING IN THE VIOLATION OF THE RULE. THE REGISTRANT FOLLOWS RIGOROUS COMPLIANCE PROCEDURES, TAKES REASONABLE STEPS TO ENFORCE ITS POLICIES, AND TRAINS AND PERIODICALLY REEDUCATES ITS EMPLOYEES OF THOSE POLICIES.