On January 25, 2024, the Commission instituted and simultaneously settled administrative and cease-and-desist proceedings (the “Order”) against Claire P. Shaughnessy (“Shaughnessy” or the “Respondent”). In the Order, the Commission found misconduct by registered investment adviser Shaughnessy, a partner and investment adviser representative of Aon Investments USA Inc., fka Aon Hewitt Investment Consulting, Inc. (“Aon”) that was inconsistent with her duty to her client, the Pennsylvania Public School Employees’ Retirement System (“PSERS”) under the Advisers Act. According to the Order, from 2013 through 2023, Aon has acted as an investment adviser for PSERS and provided certain investment advisory and investment consulting services to PSERS pursuant to a written agreement. From 2013 until December 2022, Shaughnessy was the lead partner on Aon’s engagement with PSERS. As set out in its agreement with PSERS, Aon was responsible for, among other things, calculating PSERS’s investment returns, which were then used for calculating what is known as “risk share.” Risk share is a provision in the Pennsylvania Pension Code that requires certain public school employees to contribute more to the retirement fund if certain annualized investment return targets, or “hurdles,” are not met. As lead partner, Shaughnessy provided investment advisory services to PSERS and was in charge of Aon’s calculation of PSERS’s investment performance and the risk share return rate calculation.

The Commission found that Respondent acted inconsistent with her duties as an investment adviser to PSERS by failing to adequately investigate a discrepancy between the underlying performance data used by Respondent to calculate the Risk Share Return Rate and the historically reported returns and by making material misstatements and omissions in communications to PSERS concerning the causes of the discrepancy and the extent to which Respondent understood those causes. As a result of the conduct described herein, Respondent violated Section 206(2) of the Advisers Act.

The Commission ordered Shaughnessy to pay $30,000 in a civil money penalty to the Commission. The Commission also created a Fair Fund, pursuant to Section 308(a) of the Sarbanes-Oxley Act of 2002, so the penalties collected could be distributed to harmed investors (the “Fair Fund”). See the Commission’s Order: IA-6535.

The Fair Fund consists of the $30,000 collected from the Respondent. The Fair Fund has been deposited in a Commission-designated account at the U.S. Department of the Treasury, and any accrued interest will be added to the Fair Fund.

For more information, please contact the Commission:

Office of Distributions
Email: ENFOfficeofDistributions@sec.gov