Action against Respondents, an investment adviser and its founder and CEO, for alleged failure to disclose conflicts of interest and misrepresentations to investors.  The SEC alleges that Respondent adviser made a loan on behalf of its funds to a Norwegian individual and his company, which was never fully repaid, and that Respondent CEO made a personal loan to the same company shortly afterward.  According to the SEC, Respondents failed to disclose this conflict of interest to investors and made false statements about diligence performed before making the loan.  Respondents have agreed to pay, jointly and severally, a civil penalty of $40,000.

SEC Order