Corinthian Capital Group, Llc

Allegations: THE ORDER ENTERED ON MAY 6, 2019 ALLEGED THAT IN 2014 AND 2015, CORINTHIAN MISUSED THE ASSETS IN A PRIVATE EQUITY FUND, CORINTHIAN EQUITY FUND II, LP ("CEF 2") BY FAILING TO APPLY A FEE OFFSET DUE TO CEF 2, IMPROPERLY USING CEF 2 ASSETS TO FUND ITS ADVISORY OPERATIONS, AND CAUSING CEF 2 TO OVERPAY APPROXIMATELY CERTAIN ORGANIZATIONAL EXPENSES. PURSUANT TO AN OFFER OF SETTLEMENT, THE SEC FOUND, AND THE RESPONDENTS NEITHER ADMITTED NOR DENIED, THAT CORINTHIAN VIOLATED SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-8 THEREUNDER AND THAT DAVID TAHAN, CORINTHIAN'S FORMER CFO, CAUSED CORINTHIAN'S VIOLATIONS OF THESE LAWS, THAT CORINTHIAN'S CEO, PETER VAN RAALTE, FAILED REASONABLY TO SUPERVISE THE FORMER CFO WITHIN THE MEANING OF SECTION 203(E)(6) OF THE ADVISERS ACT, THAT CORINTHIAN FAILED TO COMPLY WITH SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-2 (THE "CUSTODY RULE") DUE TO ITS FAILURE TO TIMELY DELIVER CERTAIN AUDITED FINANCIAL STATEMENTS FOR 2013, 2014 AND 2015, AND THAT CORINTHIAN FAILED TO ADOPT AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT IN VIOLATION OF SECTIONS 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. Status: Final Sanction Detail: THE ORDER IMPOSED A CIVIL MONETARY PENALTY OF $100,000 AND A CENSURE ON CORINTHIAN, AND A CIVIL MONETARY PENALTY OF $25,000 ON MR. VAN RAALTE. PAYMENT IS TO BE MADE IN THE FOLLOWING INSTALLMENTS. CORINTHIAN: (1) $40,000 WITHIN 10 DAYS OF THE ENTRY OF THE ORDER; (2) 30,000 WITHIN 6 MONTHS OF THE ENTRY OF THE ORDER; AND $30,000 WITHIN 12 MONTHS OF THE ORDER. MR. VAN RAALTE: (1) $10,000 WITHIN 10 DAYS OF THE ENTRY OF THE ORDER; (2) 7,500 WITHIN 6 MONTHS OF THE ENTRY OF THE ORDER; AND $7,500 WITHIN 12 MONTHS OF THE ORDER. THE FIRST INSTALLMENTS WERE PAID DURING THE WEEK OF MAY 6, 2019. Summary: THE SEC ADMINISTRATIVE ORDER IS FINAL. THE SEC CONSIDERED THE REMEDIAL ACTS AND COOPERATION EFFORTS BY CORINTHIAN IN DETERMINING TO ACCEPT THE OFFER OF SETTLEMENT. AS NOTED IN THE ORDER, BY YEAR-END 2015, CORINTHIAN REPAID THE FEE OFFSET AND REIMBURSED THE RELEVANT EXPENSES TO CEF 2 IN FULL WITH INTEREST.