On January 25, 2024, the SEC instituted settled administrative and cease-and-desist proceedings against Aon Investments USA Inc., fka Aon Hewitt Investment Consulting, Inc., stating: "This matter involves misconduct by registered investment adviser Aon that was inconsistent with its duty to its client, the Pennsylvania Public School Employees' Retirement System ("PSERS") under the Advisers Act."

On January 25, 2024, the SEC "announced settled charges against Aon Investments USA Inc., a Chicago-based registered investment adviser, and the firm's former partner, Claire P. Shaughnessy, for misleading their client, the Pennsylvania Public School Employees' Retirement System (PSERS), about the reason for a discrepancy between two different calculations by Aon of PSERS's investment returns for the same period."

The Commission ordered that: "the Division's request for an extension of time until March 25, 2025 to submit a Proposed Plan of Distribution is granted."

The SEC ordered that: "Miller Kaplan Arase LLP is appointed as the Tax Administrator for the QSF in the above-referenced proceeding."

The Commission stated: "Notice is hereby given . . . that the Division of Enforcement has submitted to the Commission a proposed plan of distribution (the “Proposed Plan”) for the distribution of monies paid in the above-captioned matters."

The SEC stated: "The Division of Enforcement submits this Proposed Plan of Distribution . . . . [T]he Plan seeks to compensate an investor who was harmed by the Respondents' misconduct, as described in the Orders, in connection with fees paid for certain investment advisory and investment consulting services."

The Commission ordered that: "for good cause shown, the time for entering an order approving or disapproving the Proposed Plan is extended to December 1, 2025."

The Commission stated: "On January 25, 2024, the Commission issued two related Orders (collectively, the "Orders") against Claire P. Shaughnessy ("Shaughnessy")1 and Aon Investments USA Inc., fka Aon Hewitt Investment Consulting, Inc. ("Aon")...In their respective Orders, the Commission ordered Aon to pay disgorgement of $495,098.50, prejudgment interest of $47,089.29 and a civil penalty of $1,000,000.00, and Shaughnessy to pay a civil penalty of $30,000.00, to the Commission. In each of the Orders, the Commission also created a Fair Fund pursuant to Section 308(a) of the Sarbanes-Oxley Act of 2002, so the funds collected can be distributed to harmed investors and ordered that the funds may be combined with any other distribution fund or fair fund arising out of the same facts that are the subject of the Orders."

The Commission Stated: "The Division of Enforcement submits this Proposed Plan of Distribution (the "Plan") to the United States Securities and Exchange Commission (the "Commission") pursuant to Rule 1101 of the Commission's Rules on Fair Fund and Disgorgement Plans (the "Commission's Rules"), 17 C.F.R. § 201.1101. This Plan provides for the distribution of a Fair Fund (the "Fair Fund") comprised of disgorgement, prejudgment interest, and civil money penalties paid by Claire P. Shaughnessy ("Shaughnessy") and Aon Investments USA Inc., fka Aon Hewitt Investment Consulting, Inc. ("Aon") (collectively, the "Respondents") in the above-captioned matters."