ADMINISTRATIVE PROCEEDING
File No. 3-21079; File No. 3-21080 File No. 3-21081 File No. 3-21082

September 15, 2022 - The Securities and Exchange Commission ("Commission" or "SEC") today separately charged Asset Management Group of Bank of Hawaii, Canaan Management, LLC, Highland Capital Partners LLC and StarVest Management, Inc., for violating the SEC's pay-to-play rule for investment advisers. The SEC found that each firm violated the rule by continuing to receive investment advisory fees from government entities following campaign contributions made by associates to elected officials or candidates for elected office.

According to the SEC's orders, the pay-to-play rule prohibits investment advisers from providing compensatory advisory services - either directly to a government client or through a pooled investment vehicle - for two years following a campaign contribution by the firm or certain associates to candidates or officials in a position to influence the selection or retention of investment advisers to manage the assets of public pension funds or other public entities. According to the SEC's orders, the four investment advisers violated the pay-to-play rule by continuing to receive compensation from government entities within two years after campaign contributions to elected officials or candidates for elected office who had influence over the selection of investment advisers for advisory services for government entities (or who could appoint someone who had such influence).

The SEC's orders find that the investment advisers willfully violated Section 206(4) and Rule 206(4)-5 thereunder of the Investment Advisers Act of 1940. Without admitting or denying the SEC's findings, the parties consented to a cease-and-desist order and to a censure and agreed to pay civil money penalties in the following amounts: Asset Management Group of Bank of Hawaii ($45,000), Canaan Management, LLC ($95,000), Highland Capital Partners LLC ($95,000) and StarVest Management, Inc. ($70,000).

The SEC's investigation was conducted by Kevin B. Currid and Louis A. Randazzo from the Enforcement Division's Public Finance Abuse Unit.