U.S. SECURITIES AND EXCHANGE COMMISSION
Litigation Release No. 25890 / November 8, 2023
Securities and Exchange Commission v. Premium Point Investments LP et al., Civil Action No. 1:18-cv-04145 (S.D.N.Y. filed Nov. 7, 2023)
SEC Obtains Judgment Against Former Hedge Fund Trader Related to Hedge Fund Valuation Scheme
On November 7, 2023, the U.S. District Court for the Southern District of New York entered a final consent judgment against Jeremy Shor, a trader for a private fund advised by now-defunct New York-based investment adviser Premium Point Investments LP, permanently enjoining him from violating the antifraud and other provisions of the federal securities laws.
According to the SEC’s complaint, Premium Point engaged in a fraudulent valuation scheme that resulted in the inflation of the value of private funds Premium Point advised by hundreds of millions of dollars from at least September 2015 through March 2016. The scheme relied on a secret deal where in exchange for sending trades to a broker-dealer, Premium Point received inflated broker quotes for mortgage-backed securities, as well as the use of “imputed” mid-point valuations, which were applied in a manner that further inflated the value of securities. This practice boosted the value of many of Premium Point’s holdings and further exaggerated returns in order to conceal poor fund performance and attract and retain investors.
The SEC’s complaint charged Shor with violations of Section 10(b) of the Securities Exchange Act of 1934 and Rules 10b-5(a) and (c) thereunder and Sections 17(a)(1) and (3) of the Securities Act of 1933, as well as with aiding and abetting violations of Sections 206(1), (2), and (4) of the Investment Advisers Act of 1940 and Rule 206(4)-8(a)(2) thereunder.
The SEC previously charged Premium Point, along with Shor, Premium Point’s CEO and chief investment officer Anilesh Ahuja, and a Premium Point portfolio manager Amin Majidi, with fraud on May 9, 2018, later amending its complaint to add Premium Point trader Ashish Dole as a defendant. On September 20, 2022, the SEC obtained final judgments on consent enjoining Premium Point and Ahuja from violating the antifraud and other provisions of the federal securities laws and ordering Ahuja to pay a civil penalty. The SEC obtained final judgments on consent enjoining Majidi and Dole from violating the antifraud and other provisions of the federal securities law on April 11, 2023.
The SEC’s litigation is led by Assistant Regional Directors Lee Greenwood and Joshua Brodsky and New York Regional Office Co-Regional Trial Counsel Preethi Krishnamurthy. The matter was investigated by the Division of Enforcement’s Complex Financial Instruments and Asset Management Units, and is supervised by Osman Nawaz, Chief of the Complex Financial Instruments Unit.