The SEC found that between July 2011 and June 2015, AEGON USA Investment Management, LLC (AUIM), a registered investment adviser, violated certain provisions of the federal securities laws in connection with the offer, sale, and management of 15 quantitative-model-based mutual funds, variable life insurance investment portfolios, and variable annuity investment portfolios (Products) and separately managed account (SMA) strategies (Strategies). AEGON marketed all of the Products and Strategies as managed using a proprietary quant model, and highlighted, when marketing certain of the Products and Strategies, their “emotionless,” “model-driven,” or “model- supported” investment management process and described how the models were supposed to operate. The SEC stated that these claims necessarily implied that the models worked as intended. The SEC found, however, that AEGON launched the Products and Strategies without first confirming that the models worked as intended and/or without disclosing any recognized risks associated with using the models. During the summer of 2013, AUIM (acting as the subadviser of the Products and Strategies) discovered that certain of the models contained errors and concluded that that these errors rendered at least one of the models “to not be fit for purpose.” AUIM stopped using, running, or relying on at least one of the models in September 2013. AUIM and TAM (the adviser of the Products) failed to disclose the models’ errors and AUIM’s decision to stop using the model to the board of trustees of Transamerica Funds.