Action against Respondent, a formerly registered investment adviser, for alleged misrepresentations to investors. According to the SEC, Respondent overstated its due diligence program with respect to certain investments and failed to disclose that it was investigating an alleged fraud connected with one of these investments. The SEC further alleges that Respondent underfunded its compliance program and failed to implement certain due diligence and monitoring policies and procedures, which resulted in compliance failures. Respondent has agreed to pay a civil penalty of $400,000. In a related proceeding, Respondent’s founder has agreed to pay a civil penalty of $45,000.