Action against Respondent, a registered investment adviser, for alleged violations of the Investment Advisers Act.  According to the SEC, Respondent failed to disclose conflicts of interest related to third-party service provider agreements and certain administrative costs charged to Respondent’s funds.  The SEC also alleges that Respondent misallocated some of its costs.  Respondent has agreed to pay disgorgement of $1,863,242, prejudgment interest of $71,070, and a civil penalty of $1 million.

SEC Order  

SEC Administrative Summary