Resilience Management, Llc

Allegations: THE ADMINISTRATIVE ORDER, ENTERED BY THE SECURITIES AND EXCHANGE COMMISSION ON JUNE 29, 2017 (THE "ORDER"), FOUND THAT FROM AT LEAST SEPTEMBER 2010 TO AUGUST 2013, RESILIENCE MANAGEMENT, LLC ("RESILIENCE") AND BASSEM MANSOUR, ITS CO-CEO ("MANSOUR"), ENGAGED IN CERTAIN BORROWING AND GENERAL PARTNER CAPITAL CONTRIBUTION PRACTICES THAT WERE NOT AUTHORIZED UNDER ITS PRIVATE EQUITY FUNDS' (THE "FUNDS") OPERATING DOCUMENTS AND WERE NOT ADEQUATELY DISCLOSED TO FUND INVESTORS. THE ORDER ALSO FOUND THAT: MISLEADING STATEMENTS WERE MADE IN CERTAIN OF THE FUNDS' CAPITAL CALL NOTICES, LIMITED PARTNERSHIP AGREEMENTS AND AUDITED FINANCIAL STATEMENTS; RESILIENCE FAILED TO MAINTAIN ACCURATE BOOKS AND RECORDS; AND RESILIENCE'S WRITTEN COMPLIANCE POLICIES AND PROCEDURES WERE INADEQUATE WITH REGARD TO THE FOREGOING. BOTH RESILIENCE AND MANSOUR CONSENTED TO THE ENTRY OF THE ORDER WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS IN THE ORDER OTHER THAN THE FACT THAT THE SEC HAS JURISDICTION. Status: Final Sanction Detail: RESILIENCE AND MANSOUR AGREED TO COMPLY WITH CERTAIN UNDERTAKINGS AS PRESCRIBED IN THE ORDER FOR THREE YEARS FOLLOWING THE ENTRY OF THE ORDER. RESILIENCE AND MANSOUR ALSO AGREED TO PAY, WITHIN 30 DAYS OF THE ENTRY OF THE ORDER, CIVIL MONETARY PENALTIES OF $250,000 AND $500,000 TO THE SEC, RESPECTIVELY. Summary: THE SEC ADMINISTRATIVE ORDER IS FINAL. EACH OF RESILIENCE'S AND MANSOUR'S CIVIL PENALTIES WERE PAID IN FULL WITHIN 30 DAYS OF THE ENTRY OF THE ORDER.