
In January 2024, the SEC charged Aon Investments USA Inc. and former partner Claire P. Shaughnessy for misconduct related to their handling of performance data for the Pennsylvania Public School Employees’ Retirement System (PSERS) (a pension fund). Aon and Shaughnessy were found to have provided misleading information about pension fund’s investment returns, which affected employee pension contributions under the “risk share” provision of the Pennsylvania Pension Code. Both Aon and Shaughnessy faced significant penalties for violating the Investment Advisers Act.
Aon, tasked with calculating PSERS’s returns, reported inaccurate performance figures in 2020, narrowly avoiding triggering additional pension contributions. Despite repeated warnings and concerns from PSERS, Aon failed to adequately investigate discrepancies and provided misleading explanations for the inaccuracies. By early 2021, Aon recalculated the return rate to 6.34%, triggering higher contributions for school employees. For these violations, Aon faced a $1 million penalty and additional financial sanctions.
Similarly, Claire P. Shaughnessy, the lead partner on the PSERS engagement, failed to investigate the discrepancies in the reported returns and provided misleading information. Her negligence, which violated Section 206(2) of the Advisers Act, resulted in a $30,000 fine and a cease-and-desist order.
Key Takeaways:
- Transparency and Accuracy: Investment advisers must prioritize transparent and accurate reporting, especially when managing public funds.
- Fiduciary Responsibility: Failing to address errors in performance reporting can lead to significant penalties and legal repercussions.
- Accountability: Both firms and individual advisers are held accountable for their actions in managing client investments.
This case serves as a reminder for all advisers to uphold their fiduciary duties and ensure that performance data is thoroughly vetted before impacting critical financial decisions. For more details, the SEC’s orders against Aon and Shaughnessy can be found here.
About Michael Rasmussen

Michael Rasmussen is the founder of United Atlantic Legal Services. He is a licensed attorney in Florida and registered solicitor in the United Kingdom. Michael has acted as General Counsel and Chief Compliance Officer to several investment advisers, including private fund managers, responsible for the management of billions of dollars in client assets.
Michael is also the founder of FinProLaw, an online learning platform where Michael has created courses designed for investment adviser compliance professionals. These courses include:
- Investment Adviser Compliance Essential for Chief Compliance Officers
- Foundations of Investment Adviser Compliance
- What is a “Security”?
- Investment Adviser Marketing Rule
- Regulation A – Exemption from Registration
- Regulation Crowdfunding – Exemption from Registration
- Regulation D – Exemption from Registration
Michael can also be found on LinkedIn.
Investment adviser firms who are also clients of United Atlantic Legal Services can receive many of these courses at a significantly reduced fee or, in some cases, at no expense. Contact us today or visit the FinProLaw to learn more.