UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934

Release No. 96000 / October 6, 2022

ADMINISTRATIVE PROCEEDING

File No. 3-20030

In the Matter of

Northern Trust Hedge Fund Services 

LLC and Northern Trust Global Fund 

Services Cayman Limited,

Respondents.

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NOTICE OF PROPOSED PLAN OF 

DISTRIBUTION AND OPPORTUNITY TO 

COMMENT

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, (“Commission’s 

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

a proposed plan of distribution (the “Proposed Plan”) for the distribution of monies paid to the 

Commission by Northern Trust Hedge Fund Services, LLC and Northern Trust Global Fund 

Services Cayman Limited (collectively, the “Respondents”) in the above-captioned matter.

On September 18, 2020, the Commission issued an 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 (the “Order”)1against the Respondents, the 

fund administrators for the LR Global Frontier Master Fund, Ltd. and two feeder funds, the LR 

Global Frontier Fund, Ltd. (offshore) and the LR Global Frontier Fund LP (onshore) 

(collectively, the “Funds”). According to the Order, from at least 2013 through mid-2017, 

Donald S. LaGuardia (“LaGuardia”), through the investment adviser he controlled, L-R 

Managers, LLC (“L-R Managers”) (collectively with LaGuardia, the “Advisers”), defrauded the 

Funds and their investors, misappropriating money from the Funds and directing that some of the 

misappropriated amounts be recorded as a promissory note and receivable “due from” L-R 

Managers to the Funds to conceal the misappropriation. The Order further finds that the 

Respondents caused the Advisers’ violations of the antifraud provisions of the Investment 

Advisers Act of 1940 by, among other things, failing to adequately escalate concerns they 

identified regarding the Advisers prior to their engagement, permitting the Advisers to make 

unsupported withdrawals, improperly accounting for account receivables, and failing to obtain 

sufficient pricing support for a significant holding of the Funds. The Commission ordered 

Northern Trust Hedge Fund Services, LLC to pay disgorgement of $15,076 and prejudgment 

interest of $2,553, and ordered the Respondents, jointly and severally, to pay a civil money 

 

1 Advisers Act Rel. No. 5585 (Sept. 18, 2020).
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penalty of $150,000. The Commission further established a Fair Fund pursuant to Section 308(a) 

of the Sarbanes-Oxley Act of 2002 (the “Northern Trust Fair Fund”), so the collected civil 

penalty, along with the collected disgorgement and interest, can be distributed to harmed 

investors. The Respondents have paid in full. 

The Northern Trust Fair Fund is comprised of the $167,629 paid by the Respondents. 

The assets of the Northern Trust Fair Fund are subject to the continuing jurisdiction and control 

of the Commission. The Northern Trust Fair Fund has been deposited in an interest-bearing 

account at the U.S. Department of Treasury’s Bureau of the Fiscal Service. Accrued interest will 

be added to, and become a part of, the Northern Trust Fair Fund. 

OPPORTUNITY FOR COMMENT

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

Proposed 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 Catherine E. Pappas, Esq., United States Securities 

and Exchange Commission, One Penn Center, 1617 JFK Blvd., Ste. 520, Philadelphia, PA 19103. 

All persons who desire to comment on the Proposed 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 e-mail to rule-comments@sec.gov.

Comments submitted should include “Administrative Proceeding File No. 3-20030” in the 

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

information that they wish to make publicly available.

THE PROPOSED PLAN

The Proposed Plan provides for the transfer of the Northern Trust Fair Fund, less any 

investment fees incurred while held at the Commission, to the Distribution Fund established in 

the related civil action, SEC v. Donald S. LaGuardia, Jr., No. 19-cv-05895 (S.D.N.Y.), for 

distribution to harmed investors in accordance with a plan to be approved by the district court.

By the Commission.

Vanessa A. Countryman

Secretary