Old Ironsides Energy, Llc

Allegations: THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ALLEGED THAT OLD IRONSIDES ENERGY, LLC ("OLD IRONSIDES") DISTRIBUTED MARKETING MATERIALS FOR A PRIVATE FUND, OLD IRONSIDES ENERGY FUND II ("FUND II"), THAT OMITTED CERTAIN INFORMATION REGARDING THE CHARACTER OF A LEGACY OIL AND NATURAL GAS INVESTMENT THAT OLD IRONSIDES' PRINCIPALS MADE WHEN MANAGING A PORTFOLIO OF APPROXIMATELY 420 INVESTMENTS FOR A PREVIOUS EMPLOYER, WHICH RENDERED THE MARKETING MATERIALS MISLEADING. SPECIFICALLY, THE SEC ALLEGED THAT THE MARKETING MATERIALS CATEGORIZED THIS INVESTMENT AS AN EARLY STAGE DIRECT DRILLING INVESTMENT IN A "TRACK RECORD" REFLECTING THE INVESTMENT PERFORMANCE OF, AMONG OTHER THINGS, LEGACY DIRECT DRILLING INVESTMENTS, BUT OMITTED INFORMATION REGARDING HOW THE INVESTMENT'S FUND STRUCTURE AND ROLE OF THE THIRD-PARTY ADVISER WHO MANAGED IT DIFFERED FROM OTHER EARLY STAGE DIRECT DRILLING INVESTMENTS IN THE TRACK RECORD. THE SEC ALSO ALLEGED THAT OLD IRONSIDES FAILED TO IMPLEMENT ITS COMPLIANCE POLICIES AND PROCEDURES PROHIBITING MARKETING MATERIALS FROM OMITTING INFORMATION NECESSARY TO AVOID MATERIALLY MISLEADING INFORMATION, WHEN IT CREATED MARKETING MATERIALS THAT CATEGORIZED THE PRIVATE FUND INVESTMENT AS AN EARLY STAGE DIRECT DRILLING INVESTMENT. Status: Final Sanction Detail: PENALTY PAYMENT OF $1,000,000 MADE ON APRIL 22, 2020. Summary: ON APRIL 17, 2020, OLD IRONSIDES, WITHOUT ADMITTING OR DENYING THE FINDINGS THEREIN, ENTERED INTO A SETTLEMENT WITH THE SEC. THE SEC APPROVED THE ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER, INCLUDING THE FOLLOWING TERMS AND CONDITIONS. OLD IRONSIDES AGREED TO CEASE AND DESIST FROM VIOLATING SECTION 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 AND RULES 206(4)-1 AND 206(4)-7 THEREUNDER; TO A CENSURE; AND TO PAY A $1,000,000 CIVIL MONETARY PENALTY, WHICH WAS PAID ON APRIL 22, 2020.