In re Trevor L. Taylor

 
 
 
 
 UNITED STATES OF AMERICA 
 Before the 
 SECURITIES AND EXCHANGE COMMISSION 
 
SECURITIES EXCHANGE ACT OF 1934 
Release No. 94925 / May 17, 2022 
 
INVESTMENT ADVISERS ACT OF 1940 
Release No. 6025 / May 17, 2022 
 
ADMINISTRATIVE PROCEEDING 
File No.  3-20853 
 
 
 
In the Matter of 
 
Trevor L. Taylor,   
 
Respondent. 
 
 
 
 
ORDER INSTITUTING  
ADMINISTRATIVE PROCEEDINGS 
PURSUANT TO SECTION 15(b) OF THE 
SECURITIES EXCHANGE ACT OF 1934 AND 
SECTION 203(f) OF THE INVESTMENT 
ADVISERS ACT OF 1940, MAKING FINDINGS, 
AND IMPOSING REMEDIAL SANCTIONS 
 
 
 
 
I. 
 
 The Securities and Exchange Commission (“Commission”) deems it appropriate and in the 
public interest that public administrative proceedings be, and hereby are, instituted pursuant to 
Section 15(b) of the Securities Exchange Act of 1934 (“Exchange Act”) and Section 203(f) of the 
Investment Advisers Act of 1940 (“Advisers Act”) against Trevor L. Taylor (“Respondent”).   
 
II. 
 
 In anticipation of the institution of these proceedings, Respondent has submitted an Offer of 
Settlement (“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, Respondent admits the Commission’s jurisdiction over him and the 
subject matter of these proceedings, and the findings contained in paragraph III.2  below, which are 
admitted, and consents to the entry of this Order Instituting Administrative Proceedings Pursuant to 

 2 
Section 15(b) of the Securities Exchange Act of 1934 and Section 203(f) of the Investment Advisers 
Act of 1940, Making Findings, and Imposing Remedial Sanctions (“Order”), as set forth below.   
 
III. 
 
 On the basis of this Order and Respondent’s Offer, the Commission finds that  
 
1. Taylor, 50 years old, is a resident of Miami, Florida. During the time period of the 
alleged misconduct in paragraph 3, below, Taylor was a Managing Director at Allianz Global 
Investors U.S. LLC (“AGI US”), a registered investment adviser headquartered in New York, New 
York, under common control with Allianz Global Investors Distributors LLC, a registered broker-
dealer. In that role, Taylor served as Co-Lead Portfolio Manager for a complex options trading 
strategy (“Structured Alpha”) that AGI US marketed and sold to approximately 114 institutional 
investors in 17 unregistered private funds. 
 
2. On March 8, 2022, Taylor pled guilty to conspiracy to commit securities fraud, 
investment adviser fraud, and wire fraud in violation of 18 U.S.C. § 371; securities fraud in 
violation of 15 U.S.C. § 78j(b), 15 U.S.C. § 78ff, 17 C.F.R. § 240.10b-5, and 18 U.S.C. § 2; and 
investment adviser fraud in violation of 15 U.S.C. § 80b-6, 15 U.S.C. § 80b-17, and 18 U.S.C. § 2, 
before the United States District Court for the Southern District of New York, in United States v. 
Trevor Taylor, Case No. 22-cr-149 (DLC ) (S.D.N.Y.). 
 
 3. The counts of the criminal information to which Taylor pled guilty alleged that, 
inter alia, from in or about 2015 through in or about 2020, Taylor and others engaged in a scheme 
to defraud investors in the Structured Alpha funds by making false and misleading statements to 
current and prosepective investors that substantially understated the risks being taken by the funds.   
 
IV. 
 
 In view of the foregoing, the Commission deems it appropriate and in the public interest to 
impose the sanctions agreed to in Respondent Taylor’s Offer. 
 
 Accordingly, it is hereby ORDERED pursuant to Section 15(b)(6) of the Exchange Act, 
and Section 203(f) of the Advisers Act, that Respondent Taylor be, and hereby is barred from 
association with any broker, dealer, investment adviser, municipal securities dealer, municipal 
advisor, transfer agent, or nationally recognized statistical rating organization; and 
 
 Pursuant to Section 15(b)(6) of the Exchange Act Respondent Taylor be, and hereby is 
barred from participating in any offering of a penny stock, including: acting as a promoter, finder, 
consultant, agent or other person who engages in activities with a broker, dealer or issuer for 
purposes of the issuance or trading in any penny stock, or inducing or attempting to induce the 
purchase or sale of any penny stock. 
 
Any reapplication for association by the Respondent will be subject to the applicable laws 
and regulations governing the reentry process, and reentry may be conditioned upon a number of 

 3 
factors, including, but not limited to, compliance with the Commission’s order and payment of any 
or all of the following:  (a) any disgorgement or civil penalties ordered by a Court against the 
Respondent in any action brought by the Commission; (b) any disgorgement amounts ordered 
against the Respondent for which the Commission waived payment; (c) any arbitration award 
related to the conduct that served as the basis for the Commission order; (d) any self-regulatory 
organization arbitration award to a customer, whether or not related to the conduct that served as 
the basis for the Commission order; and (e) any restitution order by a self-regulatory organization, 
whether or not related to the conduct that served as the basis for the Commission order. 
 
 By the Commission. 
 
  
 
 
 
Vanessa A. Countryman 
Secretary 
 

UNITED STATES OF AMERICA 

 Before the 

 SECURITIES AND EXCHANGE COMMISSION 

 

SECURITIES EXCHANGE ACT OF 1934 

Release No. 94925 / May 17, 2022 

 

INVESTMENT ADVISERS ACT OF 1940 

Release No. 6025 / May 17, 2022 

 

ADMINISTRATIVE PROCEEDING 

File No.  3-20853 

 

 

 

In the Matter of 

 

Trevor L. Taylor,   

 

Respondent. 

 

 

 

 

ORDER INSTITUTING  

ADMINISTRATIVE PROCEEDINGS 

PURSUANT TO SECTION 15(b) OF THE 

SECURITIES EXCHANGE ACT OF 1934 AND 

SECTION 203(f) OF THE INVESTMENT 

ADVISERS ACT OF 1940, MAKING FINDINGS, 

AND IMPOSING REMEDIAL SANCTIONS 

 

 

 

 

I. 

 

 The Securities and Exchange Commission (“Commission”) deems it appropriate and in the 

public interest that public administrative proceedings be, and hereby are, instituted pursuant to 

Section 15(b) of the Securities Exchange Act of 1934 (“Exchange Act”) and Section 203(f) of the 

Investment Advisers Act of 1940 (“Advisers Act”) against Trevor L. Taylor (“Respondent”).   

 

II. 
 

 In anticipation of the institution of these proceedings, Respondent has submitted an Offer of 

Settlement (“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, Respondent admits the Commission’s jurisdiction over him and the 

subject matter of these proceedings, and the findings contained in paragraph III.2  below, which are 

admitted, and consents to the entry of this Order Instituting Administrative Proceedings Pursuant to 



 2 

Section 15(b) of the Securities Exchange Act of 1934 and Section 203(f) of the Investment Advisers 

Act of 1940, Making Findings, and Imposing Remedial Sanctions (“Order”), as set forth below.   

 

III. 

 

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

 

1. Taylor, 50 years old, is a resident of Miami, Florida. During the time period of the 

alleged misconduct in paragraph 3, below, Taylor was a Managing Director at Allianz Global 

Investors U.S. LLC (“AGI US”), a registered investment adviser headquartered in New York, New 

York, under common control with Allianz Global Investors Distributors LLC, a registered broker-

dealer. In that role, Taylor served as Co-Lead Portfolio Manager for a complex options trading 

strategy (“Structured Alpha”) that AGI US marketed and sold to approximately 114 institutional 

investors in 17 unregistered private funds. 

 

2. On March 8, 2022, Taylor pled guilty to conspiracy to commit securities fraud, 

investment adviser fraud, and wire fraud in violation of 18 U.S.C. § 371; securities fraud in 

violation of 15 U.S.C. § 78j(b), 15 U.S.C. § 78ff, 17 C.F.R. § 240.10b-5, and 18 U.S.C. § 2; and 

investment adviser fraud in violation of 15 U.S.C. § 80b-6, 15 U.S.C. § 80b-17, and 18 U.S.C. § 2, 

before the United States District Court for the Southern District of New York, in United States v. 

Trevor Taylor, Case No. 22-cr-149 (DLC ) (S.D.N.Y.). 

 

 3. The counts of the criminal information to which Taylor pled guilty alleged that, 

inter alia, from in or about 2015 through in or about 2020, Taylor and others engaged in a scheme 

to defraud investors in the Structured Alpha funds by making false and misleading statements to 

current and prosepective investors that substantially understated the risks being taken by the funds.   

 

IV. 

 

 In view of the foregoing, the Commission deems it appropriate and in the public interest to 

impose the sanctions agreed to in Respondent Taylor’s Offer. 

 

 Accordingly, it is hereby ORDERED pursuant to Section 15(b)(6) of the Exchange Act, 

and Section 203(f) of the Advisers Act, that Respondent Taylor be, and hereby is barred from 

association with any broker, dealer, investment adviser, municipal securities dealer, municipal 

advisor, transfer agent, or nationally recognized statistical rating organization; and 

 

 Pursuant to Section 15(b)(6) of the Exchange Act Respondent Taylor be, and hereby is 

barred from participating in any offering of a penny stock, including: acting as a promoter, finder, 

consultant, agent or other person who engages in activities with a broker, dealer or issuer for 

purposes of the issuance or trading in any penny stock, or inducing or attempting to induce the 

purchase or sale of any penny stock. 

 

Any reapplication for association by the Respondent will be subject to the applicable laws 

and regulations governing the reentry process, and reentry may be conditioned upon a number of 



 3 

factors, including, but not limited to, compliance with the Commission’s order and payment of any 

or all of the following:  (a) any disgorgement or civil penalties ordered by a Court against the 

Respondent in any action brought by the Commission; (b) any disgorgement amounts ordered 

against the Respondent for which the Commission waived payment; (c) any arbitration award 

related to the conduct that served as the basis for the Commission order; (d) any self-regulatory 

organization arbitration award to a customer, whether or not related to the conduct that served as 

the basis for the Commission order; and (e) any restitution order by a self-regulatory organization, 

whether or not related to the conduct that served as the basis for the Commission order. 

 

 By the Commission. 

 

  

 

 

 

Vanessa A. Countryman 

Secretary