In the Matter of Laurence I. Balter d/b/a Oracle Investment Research
Admin. Proc. File No. 3-17614

On May 26, 2017, the Commission instituted and simultaneously settled cease-and-desist proceedings (the "Order") against Laurence I. Balter d/b/a Oracle Investment Research, a formerly registered investment adviser to Oracle Mutual Fund (the "Fund") and between 100 and 120 separate accounts ("SMAs") (the "Respondent"). In the Order, the Commission found that, from January 2011 to April 2014, the Respondent engaged in three distinct violations resulting in multiple breaches of his fiduciary duty and violations of the antifraud provisions of the federal securities laws. First, the Respondent fraudulently allocated profitable trades to his own accounts to the detriment of several client accounts. Second, the Respondent falsely told his SMA clients who invested in the Fund that they would not pay both advisory fees and Fund management fees for the portions of their accounts invested in the Fund. Third, the Respondent made trades for the Fund that deviated from two of its fundamental investment limitations. Together, the violations caused significant harm to the Respondent's clients. The Commission ordered the Respondent to pay a total of $550,000.00 in disgorgement, prejudgment interest, and civil money penalty to the Commission, pursuant to a three year payment plan. The Commission also created a Fair Fund, pursuant to Section 308(a) of the Sarbanes-Oxley Act of 2002, as amended, so the penalty, along with the disgorgement and prejudgment interest, collected can be distributed to those harmed by the Respondent's conduct. See the Commission's Order: Release No. 33-10367.

Office of Distributions
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