On February 24, 2020, the SEC instituted settled administrative and cease-and-desist proceedings against Lone Star Value LLC and Jeffrey Eberwein. The SEC stated: "In August 2014 and November 2014, Lone Star, while reporting to the Commission as an exempt reporting investment adviser, effected 19 interfund cross trades between two funds Lone Star managed, and, in June 2015, while registered with the Commission as an investment adviser, effected 2 trades between a fund Lone Star managed and a separately managed account (the "SMA") for which Lone Star served as an investment adviser. These 21 trades were made on a principal basis because Eberwein's ownership stake in the Lone Star fund involved in each of these trades was more than 35% during the relevant time period. Lone Star failed to disclose in writing that it engaged in these principal transactions and did not obtain client consent before the completion of each of the transactions as required under Section 206(3) of the Advisers Act. . . . Lone Star also failed to implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder, a violation of Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder."