SEC v. Deerfield Management Company, L.P. (2017)

Settled

Checked against the primary document on October 3, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, with sampled and disputed records read a second time. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.

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In August 2017 the SEC settled with hedge fund adviser Deerfield Management for failing to maintain policies to prevent misuse of material non-public information from political intelligence firms. It was censured and ordered to pay $714,110 disgorgement, $97,585 interest and a $3.9 million penalty. The order charges a compliance failure, not insider trading.

The record

Structured fields for this action, as recorded in our case library.
Agency	SEC
Release number	IA-4749
Date filed	2017-08-21
Date resolved	2017-08-21
Status	settled
Asset class	equities
Criminal parallel	No
Defendants	Deerfield Management Company, L.P. (entity)
Also named elsewhere	Deerfield Management Company, L.P. is named in 1 other matter
Cited as charged or alleged	Advisers Act s.204A (statutes and rules cited in the document; not a finding that they were violated)
Techniques

What was ordered

Civil penalty: $3.9m
Disgorgement: $714k
Prejudgment interest: $97.6k
Total relief: $4.8m
Alleged gain: $3.9m

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

What is alleged to have happened

The Commission found that from 2012 through 2014 Deerfield's policies for vetting research firms, particularly those selling political intelligence, were inadequate, and that analysts received information about pending government payment decisions before they were public and traded on recommendations drawn from it, producing profits of more than $3.9 million for hedge funds it advised.

The order, entered on consent, imposes a censure, disgorgement of $714,110, prejudgment interest of $97,585 and a civil penalty of $3,946,267. Because the violation found is the adviser's failure to maintain procedures, the insider-trading tag has been removed.

Timeline

2017-08-21 Administrative proceeding instituted (cease-and-desist)

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

SEC order

The linked release is a work of the United States government and is not subject to copyright. Our summary and narrative above are our own writing.

Record added September 10, 2026. submit a correction.