thereunder, and this deficiency resulted from the requirement that NES take a haircut of $35.3 million due to its error account activity related to the Facebook IPO; and prior to the haircut. NES1s excess net capital was approximately $8.8 million.. 05/29/2013. SEC Administrative Proceedings - 2013 • REG - Reg

ell over $100 for Facebook. In addition to the valuation discrepancy, we also liked the technical aspects of the trade. Our perception was that post the Facebook IPO, GSVC would go from being a use of cash for investors to a source of cash as they reallocated into Facebook directly. After the Facebook IPO, GSVC'