In re Barrington Asset

UNITED STATES OF AMERICA 
 Before the 
 SECURITIES AND EXCHANGE COMMISSION 
 
SECURITIES EXCHANGE ACT OF 1934 
Release No. 104793 / February 10, 2026 
 
INVESTMENT ADVISERS ACT OF 1940 
Release No. 6944 / February 10, 2026 
 
INVESTMENT COMPANY ACT OF 1940 
Release No. 35946 / February 10, 2026 
 
ADMINISTRATIVE PROCEEDING 
File No. 3-22590 
 
In the Matter of 
 

Barrington Asset 
Management, Inc. and 
Gregory David Paris 

 
Respondents. 
 
 
 
 

ORDER INSTITUTING ADMINISTRATIVE 
AND CEASE-AND-DESIST PROCEEDINGS, 
PURSUANT TO SECTION 15(b) OF THE 
SECURITIES EXCHANGE ACT OF 1934, 
SECTIONS 203(e), 203(f), AND 203(k) OF 
THE INVESTMENT ADVISERS ACT OF 
1940, AND SECTION 9(b) OF THE 
INVESTMENT COMPANY ACT OF 1940, 
MAKING FINDINGS, AND IMPOSING 
REMEDIAL SANCTIONS AND A CEASE-
AND-DESIST ORDER  

   
 

I. 
 
 The Securities and Exchange Commission (“Commission”) deems it appropriate and in the 
public interest that public administrative and cease-and-desist proceedings be, and hereby are, 
instituted pursuant to Section 15(b) of the Securities Exchange Act of 1934 (“Exchange Act”), 
Sections 203(e), 203(f), and 203(k) of the Investment Advisers Act of 1940 (“Advisers Act”), and 
Section 9(b) of the Investment Company Act of 1940 (“Investment Company Act”) against 
Barrington Asset Management, Inc. (“Barrington”) and Gregory David Paris (“Paris”) 
(collectively, “Respondents”).   

 
II. 

 
 In anticipation of the institution of these proceedings, Respondents have submitted an Offer 
of Settlement (the “Offer”) which the Commission has determined to accept. Solely for the purpose 
of these proceedings and any other proceedings brought by or on behalf of the Commission, or to 
which the Commission is a party, and without admitting or denying the findings herein, except as 
to the Commission’s jurisdiction over them and the subject matter of these proceedings, which are 



 

 2 

admitted, and except as provided herein in Section V with respect to Paris, Respondents consent to 
the entry of this Order Instituting Administrative and Cease-and-Desist Proceedings Pursuant to 
Section 15(b) of the Securities Exchange Act of 1934, Sections 203(e), 203(f), and 203(k) of the 
Investment Advisers Act of 1940 and Section 9(b) of the Investment Company Act of 1940, 
Making Findings, and Imposing Remedial Sanctions and a Cease-and-Desist Order (“Order”), as 
set forth below. 

 
III. 

 
 On the basis of this Order and Respondents’ Offer, the Commission finds that  
 

Summary 
 
 From December 2015 through October 2019 (the “Relevant Period”), Paris, executive vice 
president and chief compliance officer of Barrington, a state-registered investment adviser, 
disproportionately allocated certain profitable securities trades to himself and certain unprofitable 
trades to his advisory clients. Paris’s disproportionate allocations disadvantaged his clients and 
breached his and Barrington’s fiduciary duties to the clients. In addition, Barrington’s disclosures to 
clients misrepresented that it reviewed employee trading, including Paris’s personal trading. As a 
result, Barrington and Paris violated Section 206(2) of the Advisers Act. 
 

Respondents 
 
 1. Barrington Asset Management, Inc. is an Illinois corporation with its principal 
place of business in Chicago, Illinois. Barrington was registered with the Commission as an 
investment adviser until October 2012. It is currently registered as an investment adviser in Illinois 
and Georgia. Barrington reported approximately $62 million in regulatory assets under management 
on its October 2025 Form ADV filing. 
 
 2. Gregory D. Paris, age 56, is a resident of Barrington, Illinois. Since 1996, Paris has 
been an investment adviser representative of Barrington and a registered representative of a 
Commission-registered broker-dealer. Since approximately 2013, Paris has been executive vice 
president and chief compliance officer of Barrington and owns a minority interest in Barrington. 
During the Relevant Period, Paris exercised Barrington’s discretionary trading authority and 
allocated securities to fewer than ten advisory client accounts.   
 

Background 
 

3. During the Relevant Period, Barrington had discretionary authority to place trades 
for each of its advisory client accounts. Rather than trading directly in individual accounts, 
however, Paris often executed trades through block trading omnibus accounts (the “Omnibus 
Accounts”). Those accounts allowed for the execution of securities transactions on behalf of one or 
more accounts without identifying in advance the specific individual account for which a trade was 



 

 3 

intended. After executing trades through the Omnibus Accounts, Paris would typically allocate 
those trades at or near the end of the trading day, either to himself or advisory clients. 

 
Disproportionate Allocation of Certain Trades 

 
4. When Paris bought stock using an Omnibus Account, he typically delayed making 

any allocation to another account until the end of the day. Paris sometimes closed out a securities 
purchase on the same day by selling a position in the Omnibus Account before allocating both the 
buy and the sell transactions to himself or a client (a “day trade”). At other times, Paris left a 
position open and allocated the purchase either to himself or a client (“a multi-day trade”). Paris 
allocated a larger number of day trades to himself, and a larger number of multi-day trades to client 
accounts. Overall, Paris’s day trades achieved cumulative gains on the first day, while his multi-
day trades achieved first day cumulative losses.  

 
5. Paris allocated to his own account a disproportionate share of both day trades and 

multi-day trades that achieved gains on the first day. He allocated to client accounts a 
disproportionate share of trades that resulted in losses on the first day. Paris’s disproportionate 
allocations of trades allowed him to achieve first day gains on trades in certain securities during the 
Relevant Period. Paris’s advisory clients, on the other hand, received first day losses during that 
same period on trades in those same securities, demonstrating that they were disadvantaged by the 
disproportionate allocations. Paris’s disproportionate allocations of trades in those securities 
resulted in the allocation of excess first-day gains to Paris of $78,490.00. 

 
6. Throughout the Relevant Period, Barrington represented to its clients in its Form 

ADV Part 2A Brochures (“Brochures”) that it “seeks to minimize the risk that any advisory 
client could be systematically advantaged or disadvantaged in connection with such batching [of 
client orders] and to ensure that all clients are treated fairly in the batching and allocation of 
portfolio transactions.” Furthermore, Barrington’s Brochures stated that it “is the expressed 
policy of our firm that no person employed by the firm shall prefer his or her own interest to that 
of an advisory client . . . thereby preventing such employee(s) from benefitting from transactions 
placed on behalf of advisory accounts.” In connection with that policy, the Brochures stated that 
“employee trading is reviewed on a regular basis.” Paris worked with a consultant to draft the 
Brochures, and he reviewed and approved the statements in the Brochures before Barrington 
disseminated them. 

 
7. Contrary to those statements, Barrington did not conduct any review of Paris’s 

trading and allocations.  
 

 8. As a result of Paris’s disproportionate trade allocations during the Relevant Period, 
and as a result of the misrepresentations in Barrington’s Brochures, Paris and Barrington breached 
their fiduciary duties to clients.  
 
 

Violation 



 

 4 

 
9. As a result of the conduct described above, Respondents willfully1 violated Section 

206(2) of the Advisers Act, which prohibits any investment adviser, by use of the mails or any 
means or instrumentality of interstate commerce, directly or indirectly, from engaging in any 
transaction, practice, or course of business which operates as a fraud or deceit upon any client or 
prospective client.  

 
Disgorgement 

 
10. The disgorgement and prejudgment interest ordered in paragraph IV.D is 

consistent with equitable principles and does not exceed Respondent Paris’s net profits from his 
violations, and will be distributed to harmed investors, if feasible. The Commission will hold 
funds paid pursuant to paragraph IV.D in an account at the United States Treasury pending a 
decision whether the Commission in its discretion will seek to distribute funds. If a distribution is 
determined feasible and the Commission makes a distribution, upon approval of the distribution 
final accounting by the Commission, any amounts remaining that are infeasible to return to 
investors, and any amounts returned to the Commission in the future that are infeasible to return 
to investors, may be transferred to the general fund of the U.S. Treasury, subject to Section 
21F(g)(3) of the Exchange Act.   

 
IV. 

 In view of the foregoing, the Commission deems it appropriate and in the public interest to 
impose the sanctions agreed to in Respondents’ Offer. 
 
 Accordingly, pursuant to Section 15(b) of the Exchange Act, Sections 203(e), 203(f) and 
203(k) of the Advisers Act, and Section 9(b) of the Investment Company Act, it is hereby 
ORDERED that: 
 

A. Respondents cease and desist from committing or causing any violations and any 
future violations of Section 206(2) of the Advisers Act.  

 
 

1  “Willfully,” for purposes of imposing relief under Section 15(b) of the Exchange Act, 
Sections 203(e) and 203(f) of the Advisers Act and Section 9(b) of the Investment 
Company Act, “‘means no more than that the person charged with the duty knows what he 
is doing.’” Wonsover v. SEC, 205 F.3d 408, 414 (D.C. Cir. 2000) (quoting Hughes v. SEC, 
174 F.2d 969, 977 (D.C. Cir. 1949)). There is no requirement that the actor “also be aware 
that he is violating one of the Rules or Acts.”  Tager v. SEC, 344 F.2d 5, 8 (2d Cir. 1965). 
The decision in The Robare Group, Ltd. v. SEC, which construed the term “willfully” for 
purposes of a differently structured statutory provision, does not alter that standard.  922 
F.3d 468, 478-79 (D.C. Cir. 2019) (setting forth the showing required to establish that a 
person has “willfully omit[ted]” material information from a required disclosure in 
violation of Section 207 of the Advisers Act). 

  



 

 5 

B. Respondent Paris be, and hereby is: 
 
suspended from association with any broker, dealer, investment adviser, 
municipal securities dealer, municipal advisor, transfer agent, or nationally 
recognized statistical rating organization; and 

 
prohibited from serving or acting as an employee, officer, director, member 
of an advisory board, investment adviser or depositor of, or principal 
underwriter for, a registered investment company or affiliated person of such 
investment adviser, depositor, or principal underwriter, 
 

for a period of six (6) months, effective on the second Monday following the entry 
of this Order. 

 
C. Respondent Barrington is censured.   

  
D. Respondent Paris shall pay disgorgement of $78,490, prejudgment interest of 

$31,048.24 and civil penalties of $40,000, to the Securities and Exchange Commission. The 
Commission may distribute civil money penalties collected in this proceeding if, in its discretion, 
the Commission orders the establishment of a Fair Fund pursuant to 15 U.S.C. § 7246, Section 
308(a) of the Sarbanes-Oxley Act of 2002. The Commission will hold funds paid pursuant to this 
paragraph in an account at the United States Treasury pending a decision whether the Commission, 
in its discretion, will seek to distribute funds or, transfer them to the general fund of the United 
States Treasury, subject to Section 21F(g)(3). Payment shall be made in the following installments: 

 
• $35,000.00 within 10 days of the entry of this Order; 
• $28,634.56 within 90 days of the entry of this Order; 
• $28,634.56 within 180 days of the entry of this Order;  
• $28,634.56 within 270 days of the entry of this Order; and 
• $28,634.56 within 360 days of the entry of this Order. 

 
Payments shall be applied first to post order interest, which accrues pursuant to SEC Rule of 
Practice 600 and pursuant to 31 U.S.C. § 3717. Prior to making the final payment set forth herein, 
Respondent Paris shall contact the staff of the Commission for the amount due. If Respondent 
Paris fails to make any payment by the date agreed and/or in the amount agreed according to the 
schedule set forth above, all outstanding payments under this Order, including post-order interest, 
minus any payments made, shall become due and payable immediately at the discretion of the staff 
of the Commission without further application to the Commission. 
 
Payment must be made in one of the following ways:   
 

(1) Respondent Paris may transmit payment electronically to the Commission, 
which will provide detailed ACH transfer/Fedwire instructions upon 
request;  



 

 6 

 
(2) Respondent Paris may make direct payment from a bank account via 

Pay.gov through the SEC website at 
http://www.sec.gov/about/offices/ofm.htm; or  

 
(3) Respondent Paris may pay by certified check, bank cashier’s check, or 

United States postal money order, made payable to the Securities and 
Exchange Commission and hand-delivered or mailed to:  

 
Enterprise Services Center 
Accounts Receivable Branch 
HQ Bldg., Room 181, AMZ-341 
6500 South MacArthur Boulevard 
Oklahoma City, OK 73169 

 
Payments by check or money order must be accompanied by a cover letter identifying Gregory 
David Paris as a Respondent in these proceedings, and the file number of these proceedings; a copy 
of the cover letter and check or money order must be sent to Joseph G. Sansone, Division of 
Enforcement, Securities and Exchange Commission, 100 Pearl Street, Suite 20-100, New York, 
NY 10004-2616. 
 
 E. Regardless of whether the Commission in its discretion orders the creation of a Fair 
Fund for the penalties ordered in this proceeding, amounts ordered to be paid as civil money penalties 
pursuant to this Order shall be treated as penalties paid to the government for all purposes, including 
all tax purposes. To preserve the deterrent effect of the civil penalty, Respondent Paris agrees that in 
any Related Investor Action, he shall not argue that he is entitled to, nor shall he benefit by, offset or 
reduction of any award of compensatory damages by the amount of any part of Respondent Paris’s 
payment of a civil penalty in this action (“Penalty Offset”). If the court in any Related Investor Action 
grants such a Penalty Offset, Respondent Paris agrees that he shall, within 30 days after entry of a 
final order granting the Penalty Offset, notify the Commission's counsel in this action and pay the 
amount of the Penalty Offset to the Securities and Exchange Commission. Such a payment shall not 
be deemed an additional civil penalty and shall not be deemed to change the amount of the civil 
penalty imposed in this proceeding. For purposes of this paragraph, a “Related Investor Action” 
means a private damages action brought against Respondent Paris by or on behalf of one or more 
investors based on substantially the same facts as alleged in the Order instituted by the Commission 
in this proceeding. 
 

V. 
It is further Ordered that, solely for purposes of exceptions to discharge set forth in Section 

523 of the Bankruptcy Code, 11 U.S.C. § 523, the findings in this Order are true and admitted by 
Respondent Paris, and further, any debt for disgorgement, prejudgment interest, civil penalty or 
other amounts due by Respondent Paris under this Order or any other judgment, order, consent 
order, decree or settlement agreement entered in connection with this proceeding, is a debt for the 

http://www.sec.gov/about/offices/ofm.htm


 

 7 

violation by Respondent Paris of the federal securities laws or any regulation or order issued under 
such laws, as set forth in Section 523(a)(19) of the Bankruptcy Code, 11 U.S.C. § 523(a)(19). 
 

 
 By the Commission. 
 
 
 

Vanessa A. Countryman 
        Secretary 
 
 
 


	UNITED STATES OF AMERICA
	In the Matter of
	Barrington Asset Management, Inc. and Gregory David Paris
	Respondents.
	Respondents
	Background
	Disgorgement

UNITED STATES OF AMERICA 
 Before the 
 SECURITIES AND EXCHANGE COMMISSION 
 
SECURITIES EXCHANGE ACT OF 1934 
Release No. 104793 / February 10, 2026 
 
INVESTMENT ADVISERS ACT OF 1940 
Release No. 6944 / February 10, 2026 
 
INVESTMENT COMPANY ACT OF 1940 
Release No. 35946 / February 10, 2026 
 
ADMINISTRATIVE PROCEEDING 
File No. 3-22590 
 
In the Matter of 
 

Barrington Asset 
Management, Inc. and 
Gregory David Paris 

 
Respondents. 
 
 
 
 

ORDER INSTITUTING ADMINISTRATIVE 
AND CEASE-AND-DESIST PROCEEDINGS, 
PURSUANT TO SECTION 15(b) OF THE 
SECURITIES EXCHANGE ACT OF 1934, 
SECTIONS 203(e), 203(f), AND 203(k) OF 
THE INVESTMENT ADVISERS ACT OF 
1940, AND SECTION 9(b) OF THE 
INVESTMENT COMPANY ACT OF 1940, 
MAKING FINDINGS, AND IMPOSING 
REMEDIAL SANCTIONS AND A CEASE-
AND-DESIST ORDER  

   
 

I. 
 
 The Securities and Exchange Commission (“Commission”) deems it appropriate and in the 
public interest that public administrative and cease-and-desist proceedings be, and hereby are, 
instituted pursuant to Section 15(b) of the Securities Exchange Act of 1934 (“Exchange Act”), 
Sections 203(e), 203(f), and 203(k) of the Investment Advisers Act of 1940 (“Advisers Act”), and 
Section 9(b) of the Investment Company Act of 1940 (“Investment Company Act”) against 
Barrington Asset Management, Inc. (“Barrington”) and Gregory David Paris (“Paris”) 
(collectively, “Respondents”).   

 
II. 

 
 In anticipation of the institution of these proceedings, Respondents have submitted an Offer 
of Settlement (the “Offer”) which the Commission has determined to accept. Solely for the purpose 
of these proceedings and any other proceedings brought by or on behalf of the Commission, or to 
which the Commission is a party, and without admitting or denying the findings herein, except as 
to the Commission’s jurisdiction over them and the subject matter of these proceedings, which are 



 

 2 

admitted, and except as provided herein in Section V with respect to Paris, Respondents consent to 
the entry of this Order Instituting Administrative and Cease-and-Desist Proceedings Pursuant to 
Section 15(b) of the Securities Exchange Act of 1934, Sections 203(e), 203(f), and 203(k) of the 
Investment Advisers Act of 1940 and Section 9(b) of the Investment Company Act of 1940, 
Making Findings, and Imposing Remedial Sanctions and a Cease-and-Desist Order (“Order”), as 
set forth below. 

 
III. 

 
 On the basis of this Order and Respondents’ Offer, the Commission finds that  
 

Summary 
 
 From December 2015 through October 2019 (the “Relevant Period”), Paris, executive vice 
president and chief compliance officer of Barrington, a state-registered investment adviser, 
disproportionately allocated certain profitable securities trades to himself and certain unprofitable 
trades to his advisory clients. Paris’s disproportionate allocations disadvantaged his clients and 
breached his and Barrington’s fiduciary duties to the clients. In addition, Barrington’s disclosures to 
clients misrepresented that it reviewed employee trading, including Paris’s personal trading. As a 
result, Barrington and Paris violated Section 206(2) of the Advisers Act. 
 

Respondents 
 
 1. Barrington Asset Management, Inc. is an Illinois corporation with its principal 
place of business in Chicago, Illinois. Barrington was registered with the Commission as an 
investment adviser until October 2012. It is currently registered as an investment adviser in Illinois 
and Georgia. Barrington reported approximately $62 million in regulatory assets under management 
on its October 2025 Form ADV filing. 
 
 2. Gregory D. Paris, age 56, is a resident of Barrington, Illinois. Since 1996, Paris has 
been an investment adviser representative of Barrington and a registered representative of a 
Commission-registered broker-dealer. Since approximately 2013, Paris has been executive vice 
president and chief compliance officer of Barrington and owns a minority interest in Barrington. 
During the Relevant Period, Paris exercised Barrington’s discretionary trading authority and 
allocated securities to fewer than ten advisory client accounts.   
 

Background 
 

3. During the Relevant Period, Barrington had discretionary authority to place trades 
for each of its advisory client accounts. Rather than trading directly in individual accounts, 
however, Paris often executed trades through block trading omnibus accounts (the “Omnibus 
Accounts”). Those accounts allowed for the execution of securities transactions on behalf of one or 
more accounts without identifying in advance the specific individual account for which a trade was 



 

 3 

intended. After executing trades through the Omnibus Accounts, Paris would typically allocate 
those trades at or near the end of the trading day, either to himself or advisory clients. 

 
Disproportionate Allocation of Certain Trades 

 
4. When Paris bought stock using an Omnibus Account, he typically delayed making 

any allocation to another account until the end of the day. Paris sometimes closed out a securities 
purchase on the same day by selling a position in the Omnibus Account before allocating both the 
buy and the sell transactions to himself or a client (a “day trade”). At other times, Paris left a 
position open and allocated the purchase either to himself or a client (“a multi-day trade”). Paris 
allocated a larger number of day trades to himself, and a larger number of multi-day trades to client 
accounts. Overall, Paris’s day trades achieved cumulative gains on the first day, while his multi-
day trades achieved first day cumulative losses.  

 
5. Paris allocated to his own account a disproportionate share of both day trades and 

multi-day trades that achieved gains on the first day. He allocated to client accounts a 
disproportionate share of trades that resulted in losses on the first day. Paris’s disproportionate 
allocations of trades allowed him to achieve first day gains on trades in certain securities during the 
Relevant Period. Paris’s advisory clients, on the other hand, received first day losses during that 
same period on trades in those same securities, demonstrating that they were disadvantaged by the 
disproportionate allocations. Paris’s disproportionate allocations of trades in those securities 
resulted in the allocation of excess first-day gains to Paris of $78,490.00. 

 
6. Throughout the Relevant Period, Barrington represented to its clients in its Form 

ADV Part 2A Brochures (“Brochures”) that it “seeks to minimize the risk that any advisory 
client could be systematically advantaged or disadvantaged in connection with such batching [of 
client orders] and to ensure that all clients are treated fairly in the batching and allocation of 
portfolio transactions.” Furthermore, Barrington’s Brochures stated that it “is the expressed 
policy of our firm that no person employed by the firm shall prefer his or her own interest to that 
of an advisory client . . . thereby preventing such employee(s) from benefitting from transactions 
placed on behalf of advisory accounts.” In connection with that policy, the Brochures stated that 
“employee trading is reviewed on a regular basis.” Paris worked with a consultant to draft the 
Brochures, and he reviewed and approved the statements in the Brochures before Barrington 
disseminated them. 

 
7. Contrary to those statements, Barrington did not conduct any review of Paris’s 

trading and allocations.  
 

 8. As a result of Paris’s disproportionate trade allocations during the Relevant Period, 
and as a result of the misrepresentations in Barrington’s Brochures, Paris and Barrington breached 
their fiduciary duties to clients.  
 
 

Violation 



 

 4 

 
9. As a result of the conduct described above, Respondents willfully1 violated Section 

206(2) of the Advisers Act, which prohibits any investment adviser, by use of the mails or any 
means or instrumentality of interstate commerce, directly or indirectly, from engaging in any 
transaction, practice, or course of business which operates as a fraud or deceit upon any client or 
prospective client.  

 
Disgorgement 

 
10. The disgorgement and prejudgment interest ordered in paragraph IV.D is 

consistent with equitable principles and does not exceed Respondent Paris’s net profits from his 
violations, and will be distributed to harmed investors, if feasible. The Commission will hold 
funds paid pursuant to paragraph IV.D in an account at the United States Treasury pending a 
decision whether the Commission in its discretion will seek to distribute funds. If a distribution is 
determined feasible and the Commission makes a distribution, upon approval of the distribution 
final accounting by the Commission, any amounts remaining that are infeasible to return to 
investors, and any amounts returned to the Commission in the future that are infeasible to return 
to investors, may be transferred to the general fund of the U.S. Treasury, subject to Section 
21F(g)(3) of the Exchange Act.   

 
IV. 

 In view of the foregoing, the Commission deems it appropriate and in the public interest to 
impose the sanctions agreed to in Respondents’ Offer. 
 
 Accordingly, pursuant to Section 15(b) of the Exchange Act, Sections 203(e), 203(f) and 
203(k) of the Advisers Act, and Section 9(b) of the Investment Company Act, it is hereby 
ORDERED that: 
 

A. Respondents cease and desist from committing or causing any violations and any 
future violations of Section 206(2) of the Advisers Act.  

 
 

1  “Willfully,” for purposes of imposing relief under Section 15(b) of the Exchange Act, 
Sections 203(e) and 203(f) of the Advisers Act and Section 9(b) of the Investment 
Company Act, “‘means no more than that the person charged with the duty knows what he 
is doing.’” Wonsover v. SEC, 205 F.3d 408, 414 (D.C. Cir. 2000) (quoting Hughes v. SEC, 
174 F.2d 969, 977 (D.C. Cir. 1949)). There is no requirement that the actor “also be aware 
that he is violating one of the Rules or Acts.”  Tager v. SEC, 344 F.2d 5, 8 (2d Cir. 1965). 
The decision in The Robare Group, Ltd. v. SEC, which construed the term “willfully” for 
purposes of a differently structured statutory provision, does not alter that standard.  922 
F.3d 468, 478-79 (D.C. Cir. 2019) (setting forth the showing required to establish that a 
person has “willfully omit[ted]” material information from a required disclosure in 
violation of Section 207 of the Advisers Act). 

  



 

 5 

B. Respondent Paris be, and hereby is: 
 
suspended from association with any broker, dealer, investment adviser, 
municipal securities dealer, municipal advisor, transfer agent, or nationally 
recognized statistical rating organization; and 

 
prohibited from serving or acting as an employee, officer, director, member 
of an advisory board, investment adviser or depositor of, or principal 
underwriter for, a registered investment company or affiliated person of such 
investment adviser, depositor, or principal underwriter, 
 

for a period of six (6) months, effective on the second Monday following the entry 
of this Order. 

 
C. Respondent Barrington is censured.   

  
D. Respondent Paris shall pay disgorgement of $78,490, prejudgment interest of 

$31,048.24 and civil penalties of $40,000, to the Securities and Exchange Commission. The 
Commission may distribute civil money penalties collected in this proceeding if, in its discretion, 
the Commission orders the establishment of a Fair Fund pursuant to 15 U.S.C. § 7246, Section 
308(a) of the Sarbanes-Oxley Act of 2002. The Commission will hold funds paid pursuant to this 
paragraph in an account at the United States Treasury pending a decision whether the Commission, 
in its discretion, will seek to distribute funds or, transfer them to the general fund of the United 
States Treasury, subject to Section 21F(g)(3). Payment shall be made in the following installments: 

 
• $35,000.00 within 10 days of the entry of this Order; 
• $28,634.56 within 90 days of the entry of this Order; 
• $28,634.56 within 180 days of the entry of this Order;  
• $28,634.56 within 270 days of the entry of this Order; and 
• $28,634.56 within 360 days of the entry of this Order. 

 
Payments shall be applied first to post order interest, which accrues pursuant to SEC Rule of 
Practice 600 and pursuant to 31 U.S.C. § 3717. Prior to making the final payment set forth herein, 
Respondent Paris shall contact the staff of the Commission for the amount due. If Respondent 
Paris fails to make any payment by the date agreed and/or in the amount agreed according to the 
schedule set forth above, all outstanding payments under this Order, including post-order interest, 
minus any payments made, shall become due and payable immediately at the discretion of the staff 
of the Commission without further application to the Commission. 
 
Payment must be made in one of the following ways:   
 

(1) Respondent Paris may transmit payment electronically to the Commission, 
which will provide detailed ACH transfer/Fedwire instructions upon 
request;  



 

 6 

 
(2) Respondent Paris may make direct payment from a bank account via 

Pay.gov through the SEC website at 
http://www.sec.gov/about/offices/ofm.htm; or  

 
(3) Respondent Paris may pay by certified check, bank cashier’s check, or 

United States postal money order, made payable to the Securities and 
Exchange Commission and hand-delivered or mailed to:  

 
Enterprise Services Center 
Accounts Receivable Branch 
HQ Bldg., Room 181, AMZ-341 
6500 South MacArthur Boulevard 
Oklahoma City, OK 73169 

 
Payments by check or money order must be accompanied by a cover letter identifying Gregory 
David Paris as a Respondent in these proceedings, and the file number of these proceedings; a copy 
of the cover letter and check or money order must be sent to Joseph G. Sansone, Division of 
Enforcement, Securities and Exchange Commission, 100 Pearl Street, Suite 20-100, New York, 
NY 10004-2616. 
 
 E. Regardless of whether the Commission in its discretion orders the creation of a Fair 
Fund for the penalties ordered in this proceeding, amounts ordered to be paid as civil money penalties 
pursuant to this Order shall be treated as penalties paid to the government for all purposes, including 
all tax purposes. To preserve the deterrent effect of the civil penalty, Respondent Paris agrees that in 
any Related Investor Action, he shall not argue that he is entitled to, nor shall he benefit by, offset or 
reduction of any award of compensatory damages by the amount of any part of Respondent Paris’s 
payment of a civil penalty in this action (“Penalty Offset”). If the court in any Related Investor Action 
grants such a Penalty Offset, Respondent Paris agrees that he shall, within 30 days after entry of a 
final order granting the Penalty Offset, notify the Commission's counsel in this action and pay the 
amount of the Penalty Offset to the Securities and Exchange Commission. Such a payment shall not 
be deemed an additional civil penalty and shall not be deemed to change the amount of the civil 
penalty imposed in this proceeding. For purposes of this paragraph, a “Related Investor Action” 
means a private damages action brought against Respondent Paris by or on behalf of one or more 
investors based on substantially the same facts as alleged in the Order instituted by the Commission 
in this proceeding. 
 

V. 
It is further Ordered that, solely for purposes of exceptions to discharge set forth in Section 

523 of the Bankruptcy Code, 11 U.S.C. § 523, the findings in this Order are true and admitted by 
Respondent Paris, and further, any debt for disgorgement, prejudgment interest, civil penalty or 
other amounts due by Respondent Paris under this Order or any other judgment, order, consent 
order, decree or settlement agreement entered in connection with this proceeding, is a debt for the 

http://www.sec.gov/about/offices/ofm.htm


 

 7 

violation by Respondent Paris of the federal securities laws or any regulation or order issued under 
such laws, as set forth in Section 523(a)(19) of the Bankruptcy Code, 11 U.S.C. § 523(a)(19). 
 

 
 By the Commission. 
 
 
 

Vanessa A. Countryman 
        Secretary 
 
 
 


	UNITED STATES OF AMERICA
	In the Matter of
	Barrington Asset Management, Inc. and Gregory David Paris
	Respondents.
	Respondents
	Background
	Disgorgement