On September 17, 2024, the SEC instituted settled cease-and-desist proceedings against Nationale-Nederlanden Powszechne Towarzystwo Emerytalne S.A., stating: "From at least December 2019 through the present, Respondent, a foreign investment adviser not registered with the Commission, had investment discretion over at least $100 million of reportable securities and was therefore obligated to file quarterly Forms 13F beginning by at least February 2020. However, Respondent failed to file Forms 13F until April 2024. From at least July 2013, Respondent met the large trader definition under Section 13(h) of the Exchange Act and Rule 13h-1 thereunder and was required to file an initial Form 13H and annual Forms 13H and amendments as appropriate thereafter. However, Respondent failed to file an initial Form 13H until April 2024."

On September 17, 2024, the SEC "today announced charges against 11 institutional investment managers for failing to fi le reports, known as Forms 13F, that they were required to fi le because they have discretion over more than $100 million in certain securities. Two of the entities, Nationale-Nederlanden Powszechne Towarzystwo Emerytalne S.A. (Nationale-Nederlanden) and NEPC, LLC, were also charged with failing to fi le Forms 13H as required for large traders who trade a significant amount of exchange-listed securities."