Action against Respondents, an investment adviser, its co-founder and CEO, and its former CFO, for alleged misuse of client funds.  According to the SEC, Respondents failed to apply a fee offset owed to a private equity client, improperly paid for internal operations with the client’s funds, and caused the client to overpay organizational expenses.  The SEC further alleges that Respondents failed to timely issue audited financial statements for the client.  Respondent investment adviser, Respondent CEO, and Respondent CFO have agreed to pay civil penalties of $100,000, $25,000, and $15,000, respectively.

SEC Order