On June 10, 2019, David Goulding was the Chief Compliance Officer (“CCO”) for The Nutmeg Group LLC (“Nutmeg”), an SEC registered investment adviser and general partner to 15 unregistered investment partnerships (“the Funds”). His responsibilities included valuing the Funds’ investments, preparing quarterly account statements for the Funds, and tracking the assets of the Funds. David Goulding allowed his father to use the Funds’ assets to pay personal expenses which were not supported by any documentation; he failed to ensure that Nutmeg and the Funds maintained accurate financial records, and he did not follow appropriate valuation standards in valuing the Funds. In addition, the Commission alleged that David Goulding owned two limited liability companies which held Fund assets, and he was paid a percentage of the proceeds from the sale of the Funds’ assets, which facts were not disclosed to the Funds’ investors. David was barred from association with any investment adviser.