In SEC v. Grant, Civ. No. 11-11538-GAO (D. Mass. Dec. 12, 2013), the SEC alleged that the defendants violated Sections 206(1) and (2) of the Investment Advisers Act of 1940 by failing to disclose that the father of one of the defendants had been barred by a prior consent decree from associating with any investment adviser, and that his father was in fact associated with the defendant investment advisers. The SEC further alleged that the defendants violated of Section 207 of the Act for failing to disclose that the father was an “advisory affiliate” of the defendants. The defendants moved for summary judgment. The court denied the motion, finding that there was “ample evidence” that the father was “associated with” the defendants in an everyday understanding of the term, but that there was a substantial question as to whether they were associated in the "specific sense" necessary to show a violation of the statute.