
From approximately late 1997 through March 2003, DAMI and DIMA (and their predecessor advisers, which are described in Section III.B of this Order) allowed certain investors to engage in short-term or excessive trading in a manner inconsistent with the respective mutual funds’ prospectus disclosures, and also withheld information with the intent to deceive these market timing arrangements to the funds’ trustees. 3. Specifically, from July 2000 through March 2003, DAMI entered into a “sticky asset” arrangement with a hedge fund. Pursuant to this arrangement, DAMI permitted the hedge fund to market time three Deutsche Bank mutual funds, in exchange for the hedge fund maintaining a static investment in the same mutual funds. This arrangement, which DAMI withheld information with the intent to deceive, violated restrictions on market timing set forth in the funds’ prospectuses.