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UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934

Release No. 78659 / August 24, 2016

ADMINISTRATIVE PROCEEDING

File No. 3-14594

____________________________________

 :

In the Matter of :

CREDIT SUISSE ALTERNATIVE :

CAPITAL, LLC (f/k/a CREDIT : NOTICE OF PROPOSED

SUISSE ALTERNATIVE CAPITAL, : PLAN OF DISTRIBUTION 

INC.), CREDIT SUISSE ASSET : AND OPPORTUNITY

MANAGEMENT, LLC, and : FOR COMMENT

SAMIR H. BHATT, : 

:

Respondents. :

____________________________________:

Notice is hereby given, pursuant to Rule 1103 of the United States Securities and 

Exchange Commission’s (“Commission”) Rules on Fair Fund and Disgorgement Plans

(“Rules”), 17 C.F.R. § 201.1103, that the Division of Enforcement has submitted to the 

Commission a proposed plan of distribution (the “Plan of Distribution” or “Plan”) for the 

distribution of monies paid in the above-captioned matter.

On October 19, 2011, the Commission issued an Order Instituting Administrative and 

Cease-And-Desist Proceedings Pursuant to Section 8A of the Securities Act of 1933 and 

Sections 203(e), 203(f), and 203(k) of the Investment Advisers Act of 1940, Making Findings, 

and Imposing Remedial Sanctions and Cease-and Desist Orders (“Order”)1against Credit Suisse 

Alternative Capital, LLC (f/k/a Credit Suisse Alternative Capital, Inc.) (“CSAC”), Credit Suisse 

Asset Management, LLC (“CSAM”), and Samir H. Bhatt (“Bhatt”) (collectively, “Respondents”) 

for violating various provisions of the federal securities laws. As set forth in the Order, CSAC, a 

registered representative, and Bhatt, the portfolio manager at CSAC, prepared the marketing 

materials for a largely synthetic collateralized debt obligation (“CDO”) known as Class V III that 

was structured and marketed by Citigroup Global Markets Inc. (“CGMI”). The marketing 

materials contained misrepresentations and omissions that defrauded investors. The 

Commission’s Order held CSAC and CSAM jointly and severally liable for a total of $2,500,000

in disgorgement, prejudgment interest, and a civil money penalty, and Bhatt liable for a $50,000 

civil money penalty. The Respondents made the payments as required by the Order.

 

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 Securities Act Rel. No. 9268 (Oct. 19, 2011).
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The Order created a fund pursuant to Section 308(a) of the Sarbanes-Oxley Act of 2002, 

as amended, for the funds paid by the Respondents (the “CSAC Fair Fund”). The CSAC Fair 

Fund is subject to the continuing jurisdiction and control of the Commission and the CSAC Fair 

Fund has been deposited in an interest-bearing account at the United States Department of 

Treasury.

OPPORTUNITY FOR COMMENT

Pursuant to this Notice, all interested persons are advised that they may obtain a copy of 

the Plan from the Commission’s public website at http://www.sec.gov/litigation/fairfundlist.htm. 

Interested persons may also obtain a written copy of the Plan by submitting a written request to 

Nancy Chase Burton, Esq., United States Securities and Exchange Commission, 100 F Street, 

NE, Washington, DC 20549-5876. All persons who desire to comment on the Plan may submit 

their comments, in writing, no later than thirty (30) days from the date of this Notice:

1. to the Office of the Secretary, United States Securities and Exchange 

Commission, 100 F Street, NE, Washington, DC 20549-1090;

2. by using the Commission’s Internet comment form 

(http://www.sec.gov/litigation/admin.shtml); or 

3. by sending an email to rule-comments@sec.gov.

Comments submitted should include “Administrative Proceeding File No. 3-14594” in the 

subject line. Comments received will be publicly available. Persons should submit only 

information that they wish to make publicly available.

THE PLAN OF DISTRIBUTION

The CSAC Fair Fund is comprised of approximately $2,550,000 paid by the Respondents 

to the Commission. As set forth in paragraph 6 of the Distribution Plan, the Distribution Plan 

seeks to transfer the CSAC Fair Fund, pursuant to Rule 1102(a) of the Rules, 17 C.F.R. § 

201.1102(a), to the court registry account established in the related Commission action, SEC v. 

Citigroup Global Markets Inc., Case No. 11-cv-7387 (S.D.N.Y.) (“CGMI Action”), to be 

combined with the CGMI Action’s distribution fund of approximately $285,000,000 for 

distribution to harmed investors in accordance with a distribution plan to be established in that 

action.

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

Brent J. Fields

Secretary