Pinegrove Venture Partners, Llc

Allegations: AS A RESULT OF AN ACQUISITION TRANSACTION THAT OCCURRED ON DECEMBER 23, 2020, THE CONTROL AND MANAGEMENT OF SVB INNOVATION CREDIT FUND VIII, L.P. ("FUND VIII") WAS CHANGED TO A NEW (AND CURRENT) GENERAL PARTNER, SVB INNOVATION CREDIT PARTNERS VIII, LLC. NOTE THAT, UPON THE CHANGE OF CONTROL, NOTICE TO THE CALIFORNIA DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION (DFPI) WAS INITIATED TO CHANGE FUND VIII'S ADDRESS, NAME, CONTACT INFORMATION, AND OTHER MANAGEMENT INFORMATION. THESE CHANGES WERE APPROVED BY THE DFPI ON OR ABOUT JUNE 4, 2021. UNFORTUNATELY, FUND VIII INADVERTENTLY MISSED THE DEADLINE TO FILE ITS ANNUAL REPORT WITH THE DFPI BY MARCH 15, 2021, AS REQUIRED BY CALIFORNIA FINANCIAL CODE 22159. THIS WAS PARTIALLY DUE TO FUND VIII NOT RECEIVING NOTICES SENT BY THE DFPI TO CFL LICENSEES BETWEEN DECEMBER 2020 AND MARCH 2021 SINCE THE DFPI HAD NOT YET COMPLETED THE PROCESS TO CHANGE FUND VIII'S CONTACT AND OTHER INFORMATION AS MENTIONED ABOVE. ON APRIL 16, 2021, THE DFPI COMMISSIONER ISSUED AN ORDER SUMMARILY REVOKING CALIFORNIA FINANCE LENDERS LICENSE PURSUANT TO FINANCIAL CODE SECTION 22715 FOR CFL LICENSE NUMBER 60DBO-65349 ("SUMMARY REVOCATION ORDER"). ON APRIL 29, 2021, FUND VIII BECAME AWARE OF THE SUMMARY REVOCATION ORDER, AND ON APRIL 30, 2021, FUND VIII SUBMITTED ITS ANNUAL REPORT TO THE DFPI. ON MAY 6, 2021, THE DFPI COMMISSIONER AND FUND VIII ENTERED INTO A CONSENT ORDER THAT RESCINDED THE SUMMARY REVOCATION ORDER THEREBY REINSTATING FUND VIII'S CFL LICENSE. FUND VIII IS CURRENTLY MANAGED BY THE INVESTMENT ADVISER. Status: Final Sanction Detail: MONETARY PENALTY IN THE AMOUNT OF $14,500 PAID ON MAY 12, 2021. Summary: THE CONSENT ORDER CONSTITUTED A FULL AND FINAL RESOLUTION OF THE ISSUE. NO FURTHER PROCEEDINGS OR ACTIONS ARE ONGOING.

Allegations: THE SECURITIES AND EXCHANGE BOARD OF INDIA ("SEBI") ALLEGED THAT: (1) PENBROOK CAPITAL ADVISORS PRIVATE LIMITED ("PENBROOK"), THE INVESTMENT MANAGER OF PENINSULA BROOKFIELD INDIA REAL ESTATE FUND (THE "FUND") AND A JOINT VENTURE BETWEEN (I) BROOKFIELD CAPITAL PARTNERS LTD (BERMUDA), A WHOLLY OWNED SUBSIDIARY OF BROOKFIELD ASSET MANAGEMENT INC., AND (II) PENINSULA LAND LTD, A THIRD-PARTY REAL ESTATE DEVELOPER); (2) THE CURRENT AND FORMER DIRECTORS OF PENBROOK, INCLUDING ANUJ RANJAN (FORMER DIRECTOR) AND SRIDHAR RENGAN (CURRENT DIRECTOR); AND (3) PENINSULA BROOKFIELD TRUSTEE PRIVATE LIMITED, (THE TRUSTEE OF THE FUND, HAVING THE SAME SHAREHOLDERS AS PENBROOK) ((1), (2) AND (3) COLLECTIVELY, THE "NOTICEES"), ACCEPTED IMPERMISSIBLY SMALL INVESTMENTS FROM CERTAIN INVESTORS IN THE FUND, FAILED TO MAINTAIN SUFFICIENTLY LARGE INVESTMENTS THEMSELVES IN THE FUND, AND EXTENDED THE TENURE OF THE FUND BEYOND THE PERMISSIBLE PERIOD, IN VIOLATION OF THE SECURITIES AND EXCHANGE BOARD OF INDIA ACT OF 1922 AND REGULATIONS FRAMED THEREUNDER (THE "SEBI ACT"). SEBI FURTHER ALLEGED THAT THE ANNUAL COMPLIANCE TEST REPORT FOR THE FUND DID NOT REFLECT THE NON-COMPLIANCE MATTERS ASSOCIATED WITH THE ALLEGED VIOLATIONS. Status: Final Sanction Detail: THE NOTICEES AGREED TO A TOTAL SETTLEMENT AMOUNT OF INR 8,500,000, OR APPROXIMATELY USD $114,865, WHICH WAS TIMELY PAID WITHOUT AN ADMISSION OR DENIAL OF GUILT. Summary: ON MARCH 19, 2021, THE NOTICEES RECEIVED A NOTICE FROM SEBI ALLEGING THAT THE NOTICEES ACCEPTED IMPERMISSIBLY SMALL INVESTMENTS FROM CERTAIN INVESTORS IN THE FUND, FAILED TO MAINTAIN SUFFICIENTLY LARGE INVESTMENTS THEMSELVES IN THE FUND, AND EXTENDED THE TENURE OF THE FUND BEYOND THE PERMISSIBLE PERIOD, IN VIOLATION OF THE SEBI ACT. THE NOTICE FURTHER ALLEGED THAT THE ANNUAL COMPLIANCE TEST REPORT FOR THE FUND DID NOT REFLECT THE NON-COMPLIANCES ASSOCIATED WITH THE ALLEGED VIOLATIONS. IN ORDER TO FULLY SETTLE THE PROCEEDING, THE NOTICEES AGREED TO PAY INR 8,500,000, OR APPROXIMATELY USD $114,865, WHICH WAS TIMELY PAID WITHOUT AN ADMISSION OR DENIAL OF GUILT.