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These proceedings concern market-timing related misconduct by ASISI as investment adviser to the American Skandia Trust (AST) portfolios that serve as a funding vehicle for variable annuities issued by American Skandia Life Assurance Corporation (ASLAC). From at least January 2000 through in or around September 2003, ASISI accommodated widespread market timing in the AST portfolios (hereafter referred to as subaccounts). 2. Throughout this period, ASISI negligently failed to consider and to investigate adequately credible complaints from the investment advisers that had been hired to sub-advise certain of ASTs sub-accounts (hereafter referred to as sub-advisers) to the effect that market timing was having a detrimental effect on the performance of the sub-accounts and negligently failed to inform the AST Board of Trustees of these complaints.