Action against Defendant, an investment adviser, in connection with an alleged scheme to misappropriate investor funds.  According to the SEC, Defendant used the money in various private funds as one pool of money, regularly moving money between funds to meet cash flow needs.  The SEC further alleges that Defendant made misrepresentations to clients regarding fund performance, management fee arrangements, and use of investor funds and overpaid himself in violation of investor agreements.  The court will determine the appropriate amount of disgorgement, prejudgment interest, and civil penalties.

SEC Litigation Release