In re Stephen G. Bond-

 
 
 
 UNITED STATES OF AMERICA 
 Before the 
 SECURITIES AND EXCHANGE COMMISSION 
 
SECURITIES EXCHANGE ACT OF 1934 
Release No. 94926 / May 17, 2022 
 
INVESTMENT ADVISERS ACT OF 1940 
Release No. 6026 / May 17, 2022 
 
ADMINISTRATIVE PROCEEDING 
File No.  3-20854 
 
 
 
In the Matter of 
 
Stephen G. Bond-
Nelson,   
 
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 Stephen G. Bond-Nelson (“Bond-
Nelson” or “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. Bond-Nelson, 51 years old, is a resident of Berkeley Heights, New Jersey.  During 
the time period of the alleged misconduct in paragraph 3, below, Bond-Nelson was a Managing 
Director at Allianz Global Investors U.S. LLC (“AGI US”), a registered investment adviser 
headquartered in New York, New York. In that role, Bond-Nelson served as a portfolio manager for 
a complex options trading strategy (“Structured Alpha”) AGI US marketed and sold to 
approximately 114 institutional investors in 17 unregistered private funds. From July 1999 through 
January 2022, Bond-Nelson (CRD#2947935) was associated with Allianz Global Investors 
Distributors LLC, a registered broker-dealer. 
 
2. On March 3, 2022, Bond-Nelson 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; 
investment adviser fraud in violation of 15 U.S.C. § 80b-6(4), 15 U.S.C. § 80b-17, 17 C.F.R. § 
275.206(4)-8, and 18 U.S.C. § 2; and conspiracy to obstruct justice in violation of 18 U.S.C. § 371, 
before the United States District Court for the Southern District of New York, in United States v. 
Stephen Bond-Nelson, Case No. 22-cr-137 (PAE) (S.D.N.Y.). 
 
 3. The counts of the criminal information to which Bond-Nelson pled guilty alleged 
that, inter alia, from in or about 2014 to in or about 2020, Bond-Nelson made multiple material 
misrepresentations, and engaged in other fraudulent and deceptive conduct, in connection with the 
offer, purchase and sale of Structured Alpha 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 Bond-Nelson’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 Bond-Nelson 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 Bond-Nelson 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. 
 

 3 
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 
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. 94926 / May 17, 2022 

 

INVESTMENT ADVISERS ACT OF 1940 

Release No. 6026 / May 17, 2022 

 

ADMINISTRATIVE PROCEEDING 

File No.  3-20854 

 

 

 

In the Matter of 

 

Stephen G. Bond-

Nelson,   

 

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 Stephen G. Bond-Nelson (“Bond-

Nelson” or “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. Bond-Nelson, 51 years old, is a resident of Berkeley Heights, New Jersey.  During 

the time period of the alleged misconduct in paragraph 3, below, Bond-Nelson was a Managing 

Director at Allianz Global Investors U.S. LLC (“AGI US”), a registered investment adviser 

headquartered in New York, New York. In that role, Bond-Nelson served as a portfolio manager for 

a complex options trading strategy (“Structured Alpha”) AGI US marketed and sold to 

approximately 114 institutional investors in 17 unregistered private funds. From July 1999 through 

January 2022, Bond-Nelson (CRD#2947935) was associated with Allianz Global Investors 

Distributors LLC, a registered broker-dealer. 

 

2. On March 3, 2022, Bond-Nelson 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; 

investment adviser fraud in violation of 15 U.S.C. § 80b-6(4), 15 U.S.C. § 80b-17, 17 C.F.R. § 

275.206(4)-8, and 18 U.S.C. § 2; and conspiracy to obstruct justice in violation of 18 U.S.C. § 371, 

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

Stephen Bond-Nelson, Case No. 22-cr-137 (PAE) (S.D.N.Y.). 

 

 3. The counts of the criminal information to which Bond-Nelson pled guilty alleged 

that, inter alia, from in or about 2014 to in or about 2020, Bond-Nelson made multiple material 

misrepresentations, and engaged in other fraudulent and deceptive conduct, in connection with the 

offer, purchase and sale of Structured Alpha 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 Bond-Nelson’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 Bond-Nelson 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 Bond-Nelson 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. 

 



 3 

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 

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