Closed Loop Partners, Llc

Allegations: THE SEC ORDER STATES THAT CLOSED LOOP PARTNERS, LLC ("CLP") (I) FAILED TO DISCLOSE CERTAIN CONFLICTS OF INTEREST TO CERTAIN OF ITS PRIVATE FUND CLIENTS ("FUNDS"), AND FAILED TO TIMELY OBTAIN THE FUNDS' APPROVAL FOR CERTAIN SHORT TERM LOANS (INCLUDING TWO ZERO INTEREST LOANS BY CLP) MADE TO THE FUNDS THAT LED TO THE CONFLICTS OF INTEREST, (II) FAILED TO TIMELY DISTRIBUTE ANNUAL AUDITED FINANCIAL STATEMENTS PREPARED IN ACCORDANCE WITH GENERALLY ACCEPTED ACCOUNTING PRINCIPLES TO THE INVESTORS OF CERTAIN FUNDS, AND (III) FAILED TO ADOPT AND IMPLEMENT CERTAIN WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT THE FOREGOING VIOLATIONS. ALTHOUGH CLP REACHED A SETTLEMENT WITH THE SEC, CLP NEITHER ADMITS NOR DENIES ANY WRONGDOING. THE SEC ORDER ACKNOWLEDGES THAT CLP LATER DISCLOSED THE LOANS AND OBTAINED RATIFICATION FROM THE RELEVANT LPACS FOR TWO OF THE FUNDS AND FROM THE SOLE INVESTOR IN THE OTHER FUND. THE SEC ALSO CREDITED CLP'S REMEDIATION, INCLUDING REVISIONS TO CLP'S COMPLIANCE PROGRAM, POLICIES AND PROCEDURES. Status: Final Sanction Detail: CLP SHALL PAY A CIVIL MONETARY PENALTY OF $250,000 TO THE SEC IN THE FOLLOWING INSTALLMENTS: $75,000 DUE WITHIN 10 DAYS OF THE ENTRY OF THE ORDER; $60,000 DUE WITHIN 90 DAYS OF THE ENTRY OF THE ORDER; $60,000 DUE WITHIN 180 DAYS OF THE ENTRY OF THE ORDER; AND $55,000 DUE WITHIN 270 DAYS OF THE ENTRY OF THE ORDER. Summary: THE SEC ADMINISTRATIVE ORDER IS FINAL AND IMPOSES NO LIMITATION ON BUSINESS ACTIVITIES OF CLOSED LOOP PARTNERS. THE CIVIL MONETARY PENALTY OF $250,000 SHALL BE PAID AS DESCRIBED IN ITEM 12 ABOVE TO THE SEC.