Action against Respondents, an investment adviser, its former CEO, and its former CFO, for alleged Investment Advisers Act violations in connection with the fraudulent use of money from private funds. According to the SEC, Respondent adviser, through Respondent CEO, caused one of its private funds to purchase interests in risky loans in order to benefit Respondent adviser. The SEC alleges that these purchases did not comply with the procedures provided in Respondent adviser’s Form ADV. The SEC further alleges that Respondent’s reported finances during the same period were improperly altered to show better returns. Respondent adviser has agreed to pay a civil penalty of $4 million. Respondent CEO has agreed to pay a civil penalty of $200,000. Respondent CFO has agreed to pay a civil penalty of $65,000.