UNITED STATES OF AMERICA

UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934

Release No. 104277 / December 1, 2025

ADMINISTRATIVE PROCEEDING

File No. 3-21836

In the Matter of

Claire P. Shaughnessy,

Respondent.

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SECOND ORDER EXTENDING TIME

TO ENTER AN ORDER APPROVING OR

DISAPPROVING PLAN OF

DISTRIBUTION

ADMINISTRATIVE PROCEEDING

File No. 3-21837

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In the Matter of

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Aon Investments USA, Inc. fka

Aon Hewitt Investment Consulting, :

Inc.,

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Respondent.

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On March 25, 2025, pursuant to Rule 1103 of the United States Securities and Exchange

Commission’s (“Commission”) Rules on Fair Fund and Disgorgement Plans (the “Commission’s

Rules”), 17 C.F.R.§ 201.1103, the Commission published a Notice of Proposed Plan of

Distribution and Opportunity to Comment 1 for the distribution of monies collected pursuant to

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Exchange Act Rel. No. 102730 (Mar. 25, 2025).

the Orders 2 in the above-captioned matters. The Notice invited public comment on the proposed

plan of distribution (the “Proposed Plan”) through April 24, 2025, and the Commission received

a public comment (the “Comment”).

Rule 1104 of the Commission’s Rules, 17 C.F.R. § 201.1104, provides in relevant part,

“[t]he order approving or disapproving the plan should be entered within 30 days after the end of

the final period allowed for comments on the proposed plan unless the Commission or the

hearing officer, by written order, allows a longer period for good cause shown.”

On May 23, 2025, the Secretary, pursuant to delegated authority, issued an order

extending the time to enter an order approving or disapproving the Proposed Plan until

December 1, 2025. 3

The Division states additional time is needed to present its recommendation to the

Commission regarding the Comments and the Proposed Plan, and therefore, good cause has been

shown to enter an order extending time to approve or disapprove the Proposed Plan until March

31, 2026.

Order Instituting Administrative and Cease-and-Desist Proceedings, Pursuant to Sections 203(f) and 203(k) of the

Investment Advisers Act of 1940, Making Findings, and Imposing Remedial Sanctions and a Cease-and-Desist

Order, Advisers Act Rel. No. 6535 (Jan. 25, 2024), (Admin. Proc. File No. 3-21836); Corrected Order Instituting

Administrative and Cease-and-Desist Proceedings, Pursuant to Sections 203(e) and 203(k) of the Investment

Advisers Act of 1940, Making Findings, and Imposing Remedial Sanctions and a Cease-and-Desist Order, Advisers

Act Rel. No. 6536 (Jan. 25, 2024), (Admin. Proc. File No. 3-21837) (collectively, the “Orders”).

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Exchange Act Rel. No. 103122 (May 23, 2025).

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Accordingly, IT IS ORDERED that pursuant to Rule 1104 of the Commission’s Rules, 4

for good cause shown, the time for entering an order approving or disapproving the Proposed

Plan is extended to March 31, 2026.

For the Commission, by the Division of Enforcement, pursuant to delegated authority. 5

Vanessa A. Countryman

Secretary

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17 C.F.R. § 201.1104.

17 C.F.R. § 200.30-4(a)(21)(i).

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