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ARTICLE · 23 MARCH 2012

SEC Uses Case To Provide Guidance On Its Cooperation Program For Individuals

Perkins Coie LLP
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On March 19, 2012, the Securities and Exchange Commission ("SEC") announced that in exchange for his substantial cooperation during the agency's enforcement action against AXA Rosenberg Group LLC and its CEO, Barr M. Rosenberg, it would not take enforcement action against an unnamed former AXA Rosenberg senior executive.

United StatesCriminal Law
Keith Miller
Keith Miller
Todd Kerr
Todd Kerr
Christopher (Chris) O'Malley
Christopher (Chris) O'Malley

On March 19, 2012, the Securities and Exchange Commission ("SEC") announced that in exchange for his substantial cooperation during the agency's enforcement action against AXA Rosenberg Group LLC and its CEO, Barr M. Rosenberg, it would not take enforcement action against an unnamed former AXA Rosenberg senior executive.

Previously, the SEC had alleged that AXA Rosenberg, an institutional money manager, concealed a material error in the computer code of the model it used to manage client assets. The coding error affected the portfolios of more than 600 of the firm's clients and resulted in losses of approximately $217 million. In 2011, AXA Rosenberg and its CEO, Barr M. Rosenberg, settled SEC enforcement actions relating to the error and resulting losses.

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