UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

INVESTMENT ADVISERS ACT OF 1940

Release No. 4643 / February 7, 2017

ADMINISTRATIVE PROCEEDING

File No. 3-17828

In the Matter of

ROSALIND HERMAN, 

Respondent.

ORDER INSTITUTING 

ADMINISTRATIVE PROCEEDINGS 

PURSUANT TO SECTION 203(f) OF THE 

INVESTMENT ADVISERS ACT OF 1940, 

AND NOTICE OF HEARING

I.

The Securities and Exchange Commission (“Commission”) deems it appropriate and in the 

public interest that public administrative proceedings be, and hereby are, instituted pursuant to 

Section 203(f) of the Investment Advisers Act of 1940 (“Advisers Act”) against Rosalind Herman 

(“Respondent” or “Herman”). 

II.

After an investigation, the Division of Enforcement alleges that:

A. RESPONDENT

1. Rosalind Herman was the President, Chief Executive Officer, and Chief 

Investment Officer of Insight Onsite Strategic Management, LLC (“Insight Onsite”), an investment 

adviser that was registered with the Commission. Herman, 61 years old, is presently incarcerated 

at FCI Danbury, in Danbury, Connecticut, and is formerly a resident of Woburn, Massachusetts.

B. RESPONDENT’S CRIMINAL CONVICTION 

2. On April 5, 2016, Herman was convicted of, inter alia, one count of 

conspiracy in violation of Title 18 of the United States Code, Section 371, one count of investment 

adviser fraud in violation of Title 15 of the United States Code, Section 80b-6 and -17, and four 

counts of wire fraud in violation of Title 18 of the United States Code, Section 1343, before the 

United States District Court for the District of Massachusetts, in United States v. Rosalind Herman, 
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Criminal Case No. 12-10015-WGY. She was sentenced to seven years in prison and ordered to 

pay $1.82 million in restitution. 

3. The criminal indictment on which Herman was convicted alleged, inter alia, 

that Herman fraudulently induced her investment clients to loan money to her and others, diverted 

clients’ funds for her and others’ uses, and lulled her clients into allowing her to continue to control 

the clients’ investments by fraudulent means. 

III.

In view of the allegations made by the Division of Enforcement, the Commission deems it 

necessary and appropriate in the public interest that public administrative proceedings be instituted 

to determine:

A. Whether the allegations set forth in Section II hereof are true and, in connection 

therewith, to afford Respondent an opportunity to establish any defenses to such allegations; and

B. What, if any, remedial action is appropriate in the public interest against Respondent 

pursuant to Section 203(f) of the Advisers Act.

IV.

IT IS ORDERED that a public hearing for the purpose of taking evidence on the questions 

set forth in Section III hereof shall be convened at a time and place to be fixed, and before an 

Administrative Law Judge to be designated by further order as provided by Rule 110 of the 

Commission's Rules of Practice, 17 C.F.R. § 201.110.

IT IS FURTHER ORDERED that Respondent shall file an Answer to the allegations 

contained in this Order within twenty (20) days after service of this Order, as provided by Rule 220 

of the Commission's Rules of Practice, 17 C.F.R. § 201.220. 

If Respondent fails to file the directed answer, or fails to appear at a hearing after being duly 

notified, the Respondent may be deemed in default and the proceedings may be determined against 

her upon consideration of this Order, the allegations of which may be deemed to be true as provided 

by Rules 155(a), 220(f), 221(f) and 310 of the Commission's Rules of Practice, 17 C.F.R. §§ 

201.155(a), 201.220(f), 201.221(f) and 201.310.

This Order shall be served forthwith upon Herman as provided for in the Commission’s 

Rules of Practice.

IT IS FURTHER ORDERED that, pursuant to Rule 360(a)(2) of the Commission’s Rules 

of Practice, 17 C.F.R. § 201.360(a)(2), the Administrative Law Judge shall issue an initial decision 

no later than 75 days from the occurrence of one of the following events: (A) The completion of 

post-hearing briefing in a proceeding where the hearing has been completed; (B) Where the 

hearing officer has determined that no hearing is necessary, upon completion of briefing on a 
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motion pursuant to Rule 250 of the Commission’s Rules of Practice, 17 C.F.R. § 201.250; or (C) 

The determination by the hearing officer that a party is deemed to be in default under Rule 155 of 

the Commission’s Rules of Practice, 17 C.F.R. § 201.155 and no hearing is necessary. 

In the absence of an appropriate waiver, no officer or employee of the Commission engaged 

in the performance of investigative or prosecuting functions in this or any factually related 

proceeding will be permitted to participate or advise in the decision of this matter, except as witness 

or counsel in proceedings held pursuant to notice. Since this proceeding is not “rule making” within 

the meaning of Section 551 of the Administrative Procedure Act, it is not deemed subject to the 

provisions of Section 553 delaying the effective date of any final Commission action.

By the Commission.

Brent J. Fields

Secretary