Defendant Name: UBS Willow Management L.L.C.

Defendant Type: Subsidiary of Public Company
Public Company Parent: UBS AG
SIC Code: 6021
CUSIP: H4209710

Initial Case Details

Legal Case Name In the Matter of UBS Willow Management L.L.C. and UBS Fund Advisor L.L.C.
First Document Date 16-Oct-2015
Initial Filing Format Administrative Action
File Number 3-16909
Allegation Type Investment Advisers/Investment Companies

Violations Alleged

Securities Act
• Sec 17(a)(2)
• Sec 17(a)(3)
Other
• Sections 206(2), 206(4) Investment Advisers Act; Rules 206(4)-8(a)(1), 206(4)-8(a)(2) Investment

Related Violations Alleged

UBS Willow Management L.L.C. is alleged to have caused UBS Willow Fund L.L.C.'s violation of Section 34(b), Rule 8b-16 Investment Company Act.

Resolutions

First Resolution Date 16-Oct-2015
Headline Total Penalty and Disgorgement $12,596,547

Related Documents:

33-9964 16-Oct-2015 Administrative Proceeding
Order Instituting Administrative and Cease-and-Desist Proceedings Pursuant to Section 8A of the Securities Act of 1933, Sections 203(e) and 203(k) of the Investment Advisers Act of 1940, and Sections 9(b) and 9(f) of the Investment Company Act of 1940, Making Findings, and Imposing Remedial Sanctions and a Cease-and-Desist Order
On October 16, 2015, the SEC instituted settled administrative and cease-and-desist proceedings against UBS Willow Management L.L.C. and UBS Fund Advisor L.L.C. According to the SEC: "These proceedings arise from UBS Willow Management's misrepresentations and omissions concerning a material change in the investment strategy of UBS Willow Fund L.L.C. (the 'Fund'), a continuously offered, closed-end, registered investment company and UBS Willow Management's only client.... In particular, the Fund's Offering Memorandum ('OM') misrepresented the Fund's investment strategy from fall 2008 to 2012 because UBS Willow Management failed to update it to reflect the change from long credit to short credit."
2015-241 19-Oct-2015 Press Release--Administrative Proceeding
Two UBS Advisory Firms Settle Charges Arising From Failure to Disclose Change in Investment Strategy; Settlement Will Return More than $13 Million to Harmed Investors
On October 19, 2015, the SEC announced a settled administrative proceeding against UBS Fund Advisor L.L.C. and UBS Willow Management L.L.C. According to the SEC, the two advisory firms failed, "to disclose a change in investment strategy by UBS Willow Fund LLC, a closed-end fund they advised."
34-82096 16-Nov-2017 Administrative Proceeding
Order Approving Final Accounting and Authorizing Transfer of the Distribution Residual to the United States Treasury
According to the SEC: "IT IS ORDERED that, Respondents shall transmit the $67,606.98 residual balance within ten (10) days of the entry of this Order to the Commission for transfer to the U.S. Treasury."

Other Defendants in Action:

UBS Fund Advisor L.L.C.