UBS advisory firms, UBS Willow Management LLC and UBS Fund Advisor LLC, agreed to pay $17.5 million to settle SEC charges arising from a failure to disclose a change in investment strategy used by UBS Willow Fund, a closed-end fund they advised. UBS Willow Fund was marketed as one that primarily invested in distressed debt, a strategy predicated on the debt increasing in value. In 2008, instead of focusing on investments in debt, UBS Willow Management had the fund purchase large quantities of credit default swaps, a strategy predicated on the debt decreasing in value. Due to this change in strategy, the fund started incurring large losses and was liquidated in 2012. UBS Willow Management did not provide adequate disclosure of the change in investment strategy to the fund’s investors or board of directors. UBS Fund Advisor, which retained ultimate control over the fund, was aware of the change in investment strategy and failed to provide appropriate supervision by allowing the change without adequate disclosure. SEC
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