Action against Respondent, a registered investment adviser, for alleged Investment Advisers Act violations.  According to the SEC, Respondent charged three private equity fund clients for $2 million worth of employee time that was not actually spent providing services to the funds.  Respondent has agreed to pay disgorgement of $2,073,988, prejudgment interest of $284,620, and a civil penalty of $375,000.

SEC Order 

SEC Administrative Summary