In the Matter of Marco Investment Management, LLC, et al.
Admin. Proc. File No. 3-17150

On March 2, 2016, the Commission instituted and simultaneously settled administrative and cease-and-desist proceedings (the “Order”) against Marco Investment Management, LLC and Steven S. Marco (collectively, the “Respondents”). In the Order, the Commission found that, from approximately 2005 to 2014, the Respondents violated federal securities laws by charging certain clients advisory fees that were calculated in a manner different from and, at times, in excess of that provided for within those clients’ respective written advisory agreements.

The Commission ordered the Respondents to pay $132,346.38 in disgorgement and prejudgment interest (“Disgorgement Fund”). The Commission also ordered the Respondents to pay $150,000.00 in civil money penalties, which was to be paid to the U.S. Treasury.

The Commission ordered the Respondents to distribute the Disgorgement Fund to impacted current and former advisory clients, pursuant to a disbursement calculation reviewed and approved by the Commission’s staff. The Respondents are responsible for distributing the Disgorgement Fund in accordance with the Order. Tax compliance and any related administrative expenses are the responsibility of the Respondents. The Order requires that the Respondents submit to the Commission staff a final accounting and certification of the disposition of the Disgorgement Fund within 180 days of the Order. See the Commission’s order: Release No. IA-4348.