Action against Respondent, a registered investment adviser, for alleged failure to disclose conflicts of interest between Respondent and its private equity fund clients and fund investors in connection with an agreement between the adviser and a group purchasing organization (“GPO”).  According to the SEC, Respondent advised private equity funds which owned portfolio companies that used the GPO, and the GPO paid Respondent compensation based on a share of the fees the GPO received from vendors as a result of portfolio companies’ purchases through the GPO.  The SEC alleges that Respondent failed to disclose this conflict of interest.  Respondent has agreed to pay disgorgement of $625,035, prejudgment interest of $65,784.78, and a civil penalty of $90,000.

SEC Order