SEC Charges Venture Capital Fund Advisor With Misleading Investors

Posted on March 10th, 2022 at 12:04 PM
SEC Charges Venture Capital Fund Advisor With Misleading Investors

From the Desk of Jim Eccleston at Eccleston Law:

The Securities and Exchange Commission (SEC) has charged venture capital fund advisor Alumni Ventures Group (AVG) with misleading clients about its management fee structure and participating in inter-fund transactions, which violated fund operating agreements.


The SEC additionally charged Michael Collins, AVG’s CEO. AVG agreed to repay $4.7 million as well as a penalty of $700,000, while Collins agreed to pay a $100,000 penalty, according to the settlement. AVG’s website and alternative marketing communications stated that its venture capital fund featured a management fee structure known as the “industry standard ‘2 and 20.’” According to the SEC’s order, the representation was misleading because some investors were led to believe that AVG would collect a two-percent management fee in each year of the funds’ 10-year term, and additionally require a 20-percent performance fee. However, AVG typically imposed management fees constituting 20 percent of an investor’s fund investment when the funds are initially collected, according to the SEC.


The SEC’s order determined that Collins allowed AVG representatives to utilize the “industry standard ‘2 and 20’” label, while Collins personally used the language with current clients and potential investors. The SEC’s order additionally found that AVG engaged in inter-fund loans and cash transfers, which breached the fund’s operating agreements.


Eccleston Law LLC represents investors and financial advisors nationwide in securities, employment, regulatory and disciplinary matters.

 

Tags: eccleston law, SEC, AVG

Return to Archive

TESTIMONIALS

Previous
Next

I have the best legal firm in the country to defend me. Awesome job!

Cindy C.

LATEST NEWS AND ARTICLES

October 17, 2025
FINRA Fines Oak Hills Securities for Private Placement Misconduct

The Financial Industry Regulatory Authority (FINRA) has censured and fined Oak Hills Securities Inc., an Oklahoma City brokerage, for multiple rule violations over five years.

October 16, 2025
FINRA Suspends Former Citigroup Advisor Over Undisclosed Business Activities

The Financial Industry Regulatory Authority (FINRA) has suspended former Citigroup representative Maximiliano Ramirez and fined him $5,000 for engaging in undisclosed outside business activities and investments.

October 15, 2025
SEC Accuses Florida Insurance Agent of $52 Million Unregistered Securities Scheme

The U.S. Securities and Exchange Commission (SEC) has filed a complaint against Florida insurance agent Charles D. Oliver, alleging he illegally sold about $52 million in unregistered oil and gas securities to roughly 50 retail investors, including retired seniors.