UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934 

Release No. 99944 / April 11, 2024

ADMINISTRATIVE PROCEEDING

File No. 3-17614

In the Matter of

Laurence I. Balter d/b/a Oracle 

Investment Research,

Respondent.

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ORDER APPROVING 

APPLICATION OF FUND 

ADMINISTRATOR FOR PAYMENT 

OF FEES AND EXPENSES AND 

AUTHORIZING THE APPROVAL 

AND PAYMENT OF FEES AND 

EXPENSES OF ADMINISTRATION

On May 26, 2017, the Commission issued an Order Making Findings, and Imposing 

Remedial Sanctions and a Cease-and-Desist Order Pursuant to Section 8A of the Securities Act 

of 1933, Section 21C of the Securities Exchange Act of 1934, Sections 203(f) and 203(k) of the 

Investment Advisers Act of 1940, and Sections 9(b) and 9(f) of the Investment Company of 1940 

(the “Order”)1against Laurence I. Balter d/b/a Oracle Investment Research (the “Respondent”).

In the Order, the Commission found that the Respondent, a former registered investment adviser 

to the Oracle Mutual Fund (the “Fund”), committed multiple breaches of fiduciary duty and 

violations of the antifraud provisions of the federal securities laws from January 2011 to April 

2014 in 100 to 120 separately managed accounts (“SMA”). According to the Order, the 

Respondent engaged in three distinct violations. First, he fraudulently allocated profitable trades 

to his own accounts to the detriment of several client accounts. Second, he falsely told his SMA 

clients who invested in the Fund that they would not pay both advisory fees and Fund 

management fees for the portions of their accounts invested in the Fund. Third, he made trades 

for the Fund that deviated from two of its fundamental investment limitations. The Commission 

found that these violations caused significant harm to Balter’s clients. The Commission ordered 

Respondent to pay $550,000.00 in disgorgement, prejudgment interest, and a civil money penalty 

to the Commission, with payments made in installments over a three-year period. The 

Commission also created a Fair Fund, pursuant to Section 308(a) of the Sarbanes-Oxley Act of 

2002, so the penalty collected, along with the disgorgement and interest collected, can be 

distributed to harmed investors (the “Fair Fund”).

1

 Securities Act Rel. No. 10367 (May 26, 2017).
2

On April 15, 2021, the Division of Enforcement, pursuant to delegated authority, issued 

an order appointing DST Asset Manager Solutions, Inc. (n/k/a SS&C GIDS, Inc.) as the fund 

administrator of the Fair Fund and setting the bond amount.

2

In accordance with Rule 1105(d) of the Commission’s Rules,3the Fund Administrator 

has submitted to the Commission staff an invoice for services rendered from April 15, 2021, 

through January 18, 2024, totaling $46,653.09. The Commission staff has reviewed the Fund 

Administrator’s invoice, confirmed that the services have been provided, and finds the fees and 

expenses of $46,653.09 to be reasonable. The Commission staff has requested that the 

Commission authorize the Office of Financial Management (“OFM”) to pay the Fund 

Administrator’s fees and expenses of $46,653.09 from the Fair Fund in accordance with Rule 

1105(e) of the Commission’s Rules.4 

Additionally, to expedite and streamline the process for future payments, the Commission 

staff has requested that the Commission authorize OFM, at the direction of an Assistant Director 

of the Office of Distributions, to pay the Fund Administrator’s fees and expenses from the Fair 

Fund so long as the total amount paid to the Fund Administrator, including the invoice to be 

paid, does not exceed the total amount of the approved cost proposal submitted by the Fund 

Administrator.

Accordingly, it is hereby ORDERED, pursuant to Rule 1105(d) of the Commission’s 

Rules,5that OFM pay the Fund Administrator’s fees and expenses of $46,653.09 from the Fair 

Fund in accordance with Rule 1105(e) of the Commission’s Rules.6 Further, OFM is authorized 

to pay, at the direction of an Assistant Director of the Office of Distributions, any fees and 

expenses of the Fund Administrator from the Fair Fund in accordance with Rule 1105(e) of the 

Commission’s Rules,7so long as the total amount paid to the Fund Administrator, including the 

invoice to be paid, does not exceed the total amount of the approved cost proposal submitted by 

the Fund Administrator.

For the Commission, by the Division of Enforcement, pursuant to delegated authority.8

Vanessa A. Countryman

Secretary

2

 Order Appointing Fund Administrator and Setting Bond, Exchange Act Rel. No. 91570 (April 15, 2021).

3

 17 C.F.R. § 201.1105(d).

4

 17 C.F.R. § 201.1105(e).

5

 17 C.F.R. § 201.1105(d).

6

 17 C.F.R. § 201.1105(e).

7

 17 C.F.R. § 201.1105(e).

8

 17 C.F.R. § 200.30-4(a)(21)(vi).