SEC v. Wolverine Trading, LLC and Wolverine Asset Management, LLC (2015)

Settled

Checked against the primary document on October 2, 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 October 2015 the SEC settled with Wolverine Trading and Wolverine Asset Management over information-barrier breaches during the TVIX exchange-traded note premium in 2012, and inadequate policies. The adviser paid $364,146 in disgorgement, $39,158 in interest and a $375,000 penalty.

The record

Structured fields for this action, as recorded in our case library.
Agency	SEC
Release number	3-16890
Date filed	2015-10-08
Date resolved	2015-10-08
Status	settled
Asset class	equities, futures
Venue	NYSE, OTC
Criminal parallel	No
Defendants	Wolverine Trading, LLC (entity) ; Wolverine Asset Management, LLC (entity)
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: $375k
Disgorgement: $364k
Prejudgment interest: $39.2k
Total relief: $778k
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 issued the order on October 8, 2015.

The order finds the two affiliates shared information about TVIX positions and an intent to request new notes during February and March 2012, contrary to their policies, and that the policies were too vague. The adviser profited by covering a short position with newly created notes.

The findings are violations of Section 15(g) of the Exchange Act and Section 204A of the Advisers Act, failures to prevent misuse of non-public information, not insider trading. The insider-trading and naked short selling tags have been removed.

For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the release.

Timeline

2015-10-08 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.