UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934

Release No. 90006 / September 25, 2020

ADMINISTRATIVE PROCEEDING 

File No. 3-19511

In the Matter of

Leonardo Cornide and 

Jorge Falcon,

Respondents.

ORDER DIRECTING FOURTH

PAYMENT OF CERTAIN FUNDS 

RECEIVED BY THE COMMISSION

On January 24, 2020, the Commission issued an Amended Order Instituting Ceaseand- Desist Proceedings Pursuant to Section 203(k) of the Investment Advisers Act of 1940, 

Making Findings, and Imposing a Cease-and-Desist Order (the “Amended Order”)1that 

amended the order issued on September 25, 2019,2 which simultaneously instituted and settled 

a cease-and- desist proceeding against Leonardo Cornide (“Cornide”) and Jorge Falcon 

(“Falcon”) (together “Respondents”). These proceedings arise out of Respondents’ failure to 

disclose conflicts of interest while acting as investment advisers to Premier Assurance Group, 

SPC Ltd. (“PSPC”), a Cayman Islands-registered insurance company.

The Commission ordered Cornide to pay disgorgement of $2,786,925 plus accrued 

interest of $274,107.19, of which $655,350 was previously paid to PSPC; and Falcon to pay 

disgorgement of $4,390,278 plus accrued interest of $414,630.27, of which $920,349.82 was 

previously paid to PSPC. The remaining disgorgement and accrued interest was ordered to be 

paid in four installments, with such payments to be completed within 360 days of the entry of 

the Order. The Commission also ordered the Respondents to each pay a $100,000 civil money

penalty to the Commission, and created a Fair Fund, pursuant to Section 308(a) of the 

Sarbanes- Oxley Act of 2002, so the penalties could be included with the disgorgement and 

accrued interest to be collected for distribution (the “Fair Fund”).

 

1 See Advisers Act Rel. No. 5366A (Jan. 24, 2020).

2 Order Instituting Cease-and-Desist Proceedings Pursuant to Section 203(k) of the Investment Advisers Act of 

1940, Making Findings, and Imposing a Cease-and-Desist Order, Advisers Act Rel. No. 5366 (Sept. 25, 2019).
2

On February 7, 2020, the Commission directed the first payment received from the 

Respondents, pursuant to the payment plan detailed in the Amended Order, in the amount of 

$800,000 for a first tranche payment to PSPC.3

On April 30, 2020, the Secretary, pursuant to delegated authority, issued an order 

directing the second payment of certain funds received by the Commission to be paid from the 

Fair Fund to PSPC. 4

On July 23, 2020, the Secretary, pursuant to delegated authority, issued an order directing 

the third payment of certain funds received by the Commission to be paid from the Fair Fund to 

PSPC.5

The Secretary has been granted authority to issue future orders directing payment of 

certain funds received by the Commission, upon the Commission’s receipt of any additional 

funds paid pursuant to the payment plan detailed in the Amended Order.

The Commission is in receipt of the fourth payments as detailed in the Amended Order.

Accordingly, it is hereby ORDERED that the Commission staff shall direct the fourth 

payment of the $2,900,000 from the Fair Fund to PSPC.

For the Commission, by its Secretary, pursuant to delegated authority.

Vanessa A. Countryman 

Secretary

 

3

 Exchange Act Rel. No. 88144 (Feb. 7, 2020).

4 Exchange Act Rel. No. 88777 (Apr. 30, 2020).

5 Exchange Act Rel. No. 89390 (July 23, 2020).