SEC v. Palmer Square Capital Management LLC (cross trading, 2020)

Settled

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In September 2020, the SEC settled charges against Palmer Square Capital Management LLC, ordering a US$450,000 penalty for 351 prearranged cross trades between client accounts that did not meet the rules for cross trades with registered investment companies.

The record

Structured fields for this action, as recorded in our case library.
Agency	SEC
Release number	3-20039
Date filed	2020-09-21
Date resolved	2020-09-21
Status	settled
Criminal parallel	No
Defendants	Palmer Square Capital Management LLC (entity)
Cited as charged or alleged	Advisers Act s.206 (statutes and rules cited in the document; not a finding that they were violated)
Techniques

What was ordered

Civil penalty: $450k
Disgorgement: —
Prejudgment interest: —
Total relief: $450k
Alleged gain: —

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 Securities and Exchange Commission announced this matter on September 21, 2020 as release 3-20039. The respondents named are Palmer Square Capital Management LLC (0 individuals, 1 entity).

The order finds that Palmer Square, an investment adviser, sold securities from one client account to another through a broker 351 times, with a markup that the buying account paid, without the required cross-trade procedures and, in 13 cases, without disclosure and consent for principal transactions. Broker markups totalled $242,193.

This library applies no technique tag to the matter. The charge is an adviser compliance violation involving client accounts. It is not a trade designed to mislead the market about price or volume.

A $450,000 civil money penalty and a censure.

Palmer Square consented to the order without admitting or denying the findings.

Timeline

2020-09-21 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.