UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934 

Release No. 98414 / September 18, 2023

ADMINISTRATIVE PROCEEDING

File No. 3-20310

In the Matter of

S&P Dow Jones Indices LLC,

Respondent.

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ORDER DIRECTING 

DISBURSEMENT OF FAIR FUND

On March 21, 2022, the Division of Enforcement, pursuant to delegated authority, 

published a Notice of Proposed Plan of Distribution and Opportunity for Comment (“Notice”),1

pursuant to Rule 1103 of the Commission’s Rules on Fair Fund and Disgorgement Plans 

(“Commission’s Rules”);2 and simultaneously posted the Proposed Plan of Distribution (the 

“Proposed Plan”). The Notice advised interested persons that they could obtain a copy of the 

Proposed Plan from the Commission’s public website or by submitting a written request to Amy 

A. Sumner, United States Securities and Exchange Commission, Byron Rogers Federal Office 

Building, 1961 Stout Street, Suite 1700, Denver, CO 80294-1961. The Notice also advised that 

all persons desiring to comment on the Proposed Plan could submit their comments, in writing, 

within 30 days of the Notice. The Commission received no comments on the Proposed Plan 

during the comment period. On May 12, 2022, the Division of Enforcement, pursuant to 

1

 Exchange Act Rel. No. 94480 (Mar. 21, 2022). 2

 17 C.F.R. § 201.1103.
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delegated authority, issued an order approving the Proposed Plan,3 and posted the approved Plan 

of Distribution (the “Plan”).

The Plan provides for the distribution of the Fair Fund, plus accumulated interest, less 

taxes, fees, and expenses, to the harmed investors according to the methodology set forth in the 

Plan. In accordance with the Plan, the Claims Bar Date4 has passed and all timely submitted 

claims have been processed by the Fund Administrator. All investors whose claims have been 

denied, in whole or in part, have been notified and provided the opportunity to cure.

Pursuant to the Plan, the Fund Administrator has submitted the Payee List to Commission 

staff with a reasonable assurances letter as to the completeness and accuracy of the information 

contained therein. The Commission staff has reviewed and accepted the payment file and 

requests, pursuant to Rule 1101(b)(6) of the Commission’s Rules, 17 C.F.R. § 201.1101(b)(6), 

that the Commission authorize the transfer of $9,048,493.23 from the Fair Fund to the Fair 

Fund’s escrow account at The Huntington National Bank in accordance with the Payee List for 

distribution by the Fund Administrator in accordance with the Plan. 

Accordingly, it is hereby ORDERED, that Commission staff shall transfer $9,048,493.23

from the Fair Fund to the Fair Fund’s escrow account at The Huntington National Bank in 

accordance with the Payee List, and the Fund Administrator shall distribute such monies in 

accordance with the Plan. 

For the Commission, by the Division of Enforcement, pursuant to delegated authority.5

Vanessa A. Countryman

Secretary 

3

 See Order Approving Plan of Distribution, Exchange Act Rel. No. 94905 (May 12, 2022). 4

 All capitalized terms used herein but not defined shall have the same meanings ascribed to them in the Plan. 5

 17 C.F.R. § 200.30-4(a)(21)(v).