The SEC charged a London-based hedge fund adviser and its former U.S. holding company with internal controls failures in In the Matter of GLG Partners, Inc., Exchange Act Release No. 71050 (Dec. 12, 2013). The defendants settled the charges by agreeing to pay $9 million. The SEC alleged that GLG’s internal control failures caused the overvaluation of the fund’s stake in an emerging market coal mining company, leading to inflated fees to the defendants and overstatement of assets under management in the holding company’s SEC filings. Despite the fact that the defendants had an independent pricing committee that valued such assets, the SEC alleged that on a number of occasions the defendants received information calling into question the valuation of the position but failed to provide that information to the independent pricing committee. The SEC alleged that the fund lacked adequate policies and procedures to ensure that such information was provided to the independent pricing committee.