X0405 TA-1/A 0001451217 XXXXXXXX 084-06349 false LIVE SEC SEI Institutional Transfer Agent, Inc. 339341 1 Freedom Valley Drive Oaks PA 19456 N 800-858-7233 N N N N Corporation Timothy Barto 08/12/2020 Vice President and Assistant Secretary NA Robert Silvestri 05/08/2008 Treasurer NA Jeff Klauder 05/30/2008 Director and Senior Vice President NA 05/14/2018 Dennis McGonigle 05/30/2008 Director and Senior Vice President NA Aaron Buser 05/30/2008 Vice President and Assistant Secretary NA Phillip Masterson 05/30/2008 Vice President NA 05/12/2021 Jay Cipriano 05/30/2008 Vice President NA SEI Investments Management Corporation 05/30/2008 Direct Parent Company E true SEI Investments Company 05/30/2008 Ultimate Parent Company E true James Ndiaye 05/30/2008 Vice President and Assistant Secretary NA 03/01/2012 Mark Nagle 05/30/2008 Director and Senior Vice President NA 10/03/2012 James F. Volk 05/30/2008 Chief Compliance Officer NA 10/03/2014 Al DelPizzo 05/30/2008 President NA 02/23/2016 Bridget Jensen 03/04/2009 Vice President NA Robert Muse 03/04/2009 President NA David McCann 08/12/2020 General Counsel and Secretary NA Stephen Meyer 06/03/2010 Director and Senior Vice President NA 12/26/2021 Mark F. McManus 12/20/2010 Vice President NA Brent N. Vasher 12/20/2010 Vice President NA Philip McCabe 10/03/2012 Director and Senior Vice President NA Keith Dietel 10/03/2014 Chief Compliance Officer NA 11/30/2021 Teresa Curley 05/24/2016 Vice President NA Michael Peterson 05/30/2018 Director and Senior Vice President NA Bridget Sudall 01/05/2022 Chief Compliance Officer NA N N N N N N N Y SEI Investments Distribution Co. and SEI Investments Company In the matter of SEI Investments Distribution Co. and SEI Investments Company 07/14/2004 Securities and Exchange Commission Order Instituting administrative and cease-and-desist proceedings, making finding and imposing remedial sanctions and a cease-and-desist order. Pursuant to settlement, SIDCO was censored, ordered to cease-and-desist from committing or causing violations and paid a civil monetary penalty. Also SEI Investments Company agreed to cease-and-desist from causing SIDCO's violations. SEI Investments Global Funds Services In the matter of SEI Investments Global Funds Services File No. 3-18457 04/26/2018 Securities and Exchange Commission The SEC's order found that SEI Investments Global Fund Services (SGFS) caused an unregistered money market fund for which SGFS served as fund accountant and administrator to violate affiliated transaction rules when that fund sold its shares to, and redeemed them from, a set of affiliated mutual funds. While the unregistered money market fund was permitted to sell its shares to, and redeem them from the mutual funds, it could do so only if it operated in conformity with certain regulatory requirements, including Rule 2A-7 and section 18 of the Investment Company Act of 1940. The order finds that, due to the manner in which SGFS performed accounting for the unregistered money market fund, it failed to satisfy those regulatory requirements from 2008 through 2012. The action has been resolved pursuant to an offer of settlement that was accepted by the SEC, as set forth in an order instituting cease-and-desist proceedings dated 4/26/18. SGFS must cease-and-desist from further violations and pa a fine of $225,000. N N N N N N N N N Y SEI Investment Distribution Co. AWC No. 2009018186201 03/13/2012 Financial Industry Regulatory Authority FINRA alleged that SIDCO violated the content standards of NASD Rule 2210 in its review of certain ETF marketing materials between January 1, 2005 and October 20, 2009 and certain hedge fund/private placement materials in 2008. FINRA further alleged that SIDCO failed to implement supervisory procedures reasonably designed to achieve compliance with the content standards of Rule 2210. To resolve this matter, SIDCO submitted a Letter of Acceptance, Waiver and Consent (AWC) to FINRA, which was accepted on 03/13/12. Without admitting or denying FINRA's findings, SIDCO accpeted and consented to the AWC, a censure and penalty of $225,000. SEI Investments Distribution Co. AWC No. 2012030611301 04/12/2013 Financial Industry Regulatory Authority FINRA found that SIDCO violated Securities Exchange Act Rule 17A-4 and FINRA Rules 2010 and 4511, because it failed to maintain and preserve certain business-related electronic communications as a result of an internal software malfunction. To resolve this matter, SIDCO submitted a Letter of Acceptance, Waiver and Consent (AWC) to FINRA, which was accepted on 4/12/13. Without admitting or denying FINRA's findings, SIDCO accpeted and consented to AWC, a censure and fine of $100,000. N N Y SEI Investments (Europe) Ltd. Final Decision Notice 11/26/2013 United Kingdom Financial Conduct Authority ("FCA") On November 26, 2013, the FCA announced a Final Decision Notice that the FCA entered into with SIEL for violations of Principle 10-Client Assets for (i) concerns with the form of SIEL's internal client money training of operations personnel; and (II) a calculation methodology in relation to FCA client money requirements (despite using a client money calculation that had been certified annually since 2007 by SIEL's Client Assets auditors as compliant, in 2012 the FCA determined that the calculation varied from the FCA's standard methodology). SIEL provides no services for SITA nor to any investors in the United States. A fine of approximately 900,000 British Pound. No deficiencies were found by the FCA in the bank accounts and trust letters used by SIEL to appropriately separate client monies from its own assets. SIEL has since remediated the identified deficiencies. N N N Bridget Jensen 610-676-3124 Vice President 01/20/2022