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Exempt Reporting Entities

Lapse in forming an Investor Advisory Committee an issue
Naya Ventures neglected to take steps to ensure that an accounting firm was engaged to perform an annual audit as the partnership agreement required
$125,000 in fines for failing to obtain client consent
Barton Stuck is currently free on bond and is awaiting sentencing
This matter arises out of fraudulent conduct by TitleCard Capital Group, LLC (“TCCG”), an exempt reporting investment adviser with the Commission, and its only managing ...
The net effect of these transactions was that MVP and its personnel were paid, either directly or through the Broker, up-front fees of between eleven ...
Montoya engaged in a scheme to defraud investors in the RMA Fund of millions of dollars. Montoya made fraudulent representations to investors concerning the RMA ...
Batchelor engaged in a fraudulent scheme by, in connection with an unregistered offering of interests in a fund to be managed by the investment adviser ...
When Michael Rothenberg discovered the SEC was investigating his Rothenberg Ventures advisory firm, he e-mailed investors to disclose that he had used $5 million of ...
The Commission’s complaint alleged that, in his role as an investment adviser, Rothenberg schemed to defraud both the venture capital funds he managed and the ...
Based on the long positions reflected in certain accounts at its prime brokers (albeit not an overall net long position in such securities across all ...
A covered associate of Respondent made a contribution to the federal election campaign of an elected state official in Wisconsin and that state office had ...
This matter arises from the failure of venture capital fund adviser Aisling to offset consulting fees against the management fees paid by certain funds it ...
One must be pretty bad in the compliance role for the SEC to bar a person from serving as CCO.   In a new settlement, ...
More evidence has appeared that if you serve as CCO at a firm that’s alleged to have perpetuated a fraud, you can suffer an enforcement action ...
These proceedings arise because Susan Diamond, the Chief Compliance Officer of Saddle River Advisors, LLP (“SRA”), made untrue statements in multiple Forms ADV that she ...
Burrill took this money to cover cash shortages in his non-Fund III related Burrill & Company businesses, pay employee salaries, and to support his lavish ...
As the SEC’s Division of Investment Management prepares a recommendation for the Commission to formally revise two advisers act rules in response to the Fast ...
(a) Exempt reporting advisers. If you are an investment adviser relying on the exemption from registering with the Commission under section 203(l) or (m) of ...
Last month, we reported the enforcement action against TL Ventures and Penn Mezzanine, two exempt-reporting advisers that thought the pay-to-play rule didn't apply to them ...
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