In the Matter of Umesh Tandon, SEC Admin. Proc. No. 3-15282. On April 18, 2013, the SEC announced it filed a settled administrative proceeding against Umesh Tandon. According to the SEC Order, Tandon told CalPERS that his advisery firm Simran Capital Management met explicit assets under management (“AUM”) requirements and managed at least $200 million. In reality, however, Simran managed about $80 million at the time. The SEC alleges that Tandon knew that Simran did not meet CalPERS’s AUM requirements. According to the SEC Order, Tandon touted Simran’s relationship with CalPERS to other potential clients and he instructed other Simran employees to do the same. Tandon and Simran employees falsely overstated the firm’s AUM in communications with employee retirement systems and other prospective clients. They also overstated the AUM in at least four of the firm’s Form ADVs filed with the SEC. In February 2012, Simran withdrew its SEC registration as an investment adviser and has since ceased operations. According to the SEC’s order, Tandon violated Sections 206(1), 206(2), and 207 of the Investment Advisers Act of 1940. Without admitting or denying the Order’s findings, Tandon agreed to be barred from the securities industry and pay disgorgement of $20,018, prejudgment interest of $1,680, and a penalty of $100,000.
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