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Email The SEC's Aberrational Performance Initiative sparked the examination of a Fund Manager, which escalated into a full-scale investigation. The Asset Management Unit identified several internal controls failures that caused the overvaluation of fund assets and inflated fees. Consequently, the SEC fined the Fund Manager nearly $9,000,000 and imposed several other requirements and restrictions upon the firm. https://www.cadwalader.com/resources/events/regulation-operations-compliance-roc-cayman-2014