Action against Respondents, an investment advisor and two of its principals, for alleged conflicts of interest and registration violations.  According to the SEC, Respondents recommended that their clients invest in a real-estate fund and failed to disclose their compensation from the same fund.  The SEC further alleges that Respondent investment adviser acted as an unregistered broker in connection with the transactions and made false statements in its SEC filings about the compensation it received from the fund.  Respondent investment advisor has agreed to pay disgorgement of $253,784, prejudgment interest of $25,163, and a civil penalty of $85,000.  Respondent principals have agreed to pay civil penalties of $50,000 and $25,000. SEC Order