Tr?id=566623520170033&ev=PageView&noscript=1

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
Quotes Bigger

I cannot thank you enough for your efforts. You have proven to be a valuable resource.

Jim T.

LATEST NEWS AND ARTICLES

1782836587 Law
June 30, 2026
FINRA Signals Stronger Enforcement Focus on Reg BI, Excessive Trading, and Best Execution

The Financial Industry Regulatory Authority (FINRA) plans to intensify its enforcement efforts against Regulation Best Interest (Reg BI) violations, excessive trading, options trading, churning, and best execution failures after bringing a record number of retail investor protection cases in 2025, according to ThinkAdvisor.

1782744905 Law
June 29, 2026
Former Arvest Wealth Representative Sanctioned by FINRA Over Improper Use of Mistaken Commission Payment

The Financial Industry Regulatory Authority (FINRA) has suspended former Arvest Wealth representative Brandon Still for 18 months and fined him $5,000 after determining that he improperly used firm funds that were mistakenly deposited into his account.

1782497406 Law
June 26, 2026
FINRA Seeks to Make Remote Inspection Program Permanent

The Financial Industry Regulatory Authority (FINRA) is seeking approval from the Securities and Exchange Commission (SEC) to make its pandemic-era remote inspections program permanent before the current pilot is scheduled to expire in June 2027, according to AdvisorHub and FINRA's summary of its recent Board of Governors meeting.