Hite Hedge Asset Management Llc

Allegations: THE SEC ALLEGED HITE PURCHASED SECURITIES IN A SECONDARY OFFERING WHEN IT SOLD SHORT SHARES OF THE SAME SECURITY DURING THE RULE 105 (REGULATION M) PERIOD. Status: Final Summary: IN FEBRUARY 2023, THE SEC AND HITE ENTERED INTO A SETTLEMENT TO RESOLVE A SINGLE VIOLATION OF RULE 105 OF REGULATION M. THE SEC FOUND THAT HITE VIOLATED RULE 105 BY PARTICIPATING IN ONE SECONDARY OFFERING IN 2021 WHILE ALSO SELLING SHORT DURING THE RESTRICTED PERIOD. HITE HAS RESOLVED THIS MATTER WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS. AS PART OF THIS RESOLUTION, HITE AGREED TO CEASE AND DESIST FROM VIOLATING AND ANY FUTURE VIOLATIONS OF RULE 105. HITE ALSO AGREED TO PAY A ONE-TIME CIVIL MONEY PENALTY OF $103,591. THE FUNDS THAT PARTICIPATED IN THE SECONDARY OFFERING WERE REQUIRED TO DISGORGE $111,629.52 AND TO PAY PREJUDGMENT INTEREST OF $4,937.24; HITE HAS REIMBURSED THE FUNDS FOR THIS DISGORGEMENT AND PREJUDGMENT INTEREST TO ENSURE THAT THERE WOULD BE NO FINANCIAL LOSS FOR INVESTORS AS A RESULT OF THIS SETTLEMENT. HITE HAS ALWAYS TAKEN RULE 105 VERY SERIOUSLY, AND THIS EVENT OCCURRED DESPITE OUR TEAM FOLLOWING THE APPROPRIATE COMPLIANCE PRACTICES BASED IN PART ON INCORRECT INFORMATION FROM THE UNDERWRITER ABOUT THE NATURE OF THE OFFERING. SINCE THIS OCCURRENCE, WE HAVE FURTHER ENHANCED OUR DOCUMENTATION AND PROCEDURES BASED ON THE KNOWLEDGE GAINED FROM THIS EXPERIENCE.

Allegations: THE SEC ALLEGED HITE HEDGE ASSET MANAGEMENT PURCHASED SECURITIES IN A SECONDARY OFFERING WHEN IT SOLD SHORT SHARES OF THE SAME SECURITY WITHIN THE RULE 105 (REGULATION M) RESTRICTED PERIOD. Status: Final Sanction Detail: N/A Summary: IN FEBRUARY 2023, THE SEC AND HITE ENTERED INTO A SETTLEMENT TO RESOLVE A SINGLE VIOLATION OF RULE 105 OF REGULATION M. THE SEC FOUND THAT HITE VIOLATED RULE 105 BY PARTICIPATING IN ONE SECONDARY OFFERING IN 2021 WHILE ALSO SELLING SHORT DURING THE RESTRICTED PERIOD. HITE HAS RESOLVED THIS MATTER WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS. AS PART OF THIS RESOLUTION, HITE AGREED TO CEASE AND DESIST FROM VIOLATING AND ANY FUTURE VIOLATIONS OF RULE 105. HITE ALSO AGREED TO PAY A ONE-TIME CIVIL MONEY PENALTY OF $103,591. THE FUNDS THAT PARTICIPATED IN THE SECONDARY OFFERING WERE REQUIRED TO DISGORGE $111,629.52 AND TO PAY PREJUDGMENT INTEREST OF $4,937.24; HITE HAS REIMBURSED THE FUNDS FOR THIS DISGORGEMENT AND PREJUDGMENT INTEREST TO ENSURE THAT THERE WOULD BE NO FINANCIAL LOSS FOR INVESTORS AS A RESULT OF THIS SETTLEMENT. HITE HAS ALWAYS TAKEN RULE 105 VERY SERIOUSLY, AND THIS EVENT OCCURRED DESPITE OUR TEAM FOLLOWING THE APPROPRIATE COMPLIANCE PRACTICES BASED IN PART ON INCORRECT INFORMATION FROM THE UNDERWRITER ABOUT THE NATURE OF THE OFFERING. SINCE THIS OCCURRENCE, WE HAVE FURTHER ENHANCED OUR DOCUMENTATION AND PROCEDURES BASED ON THE KNOWLEDGE GAINED FROM THIS EXPERIENCE.