On May 6, 2019, Corinthian Capital Group, LLC, Peter B. Van Raalte, and David G. Tahan settled an enforcement action. From at least April 2014 to February 2015, Corinthian misused the assets in a private equity fund, Corinthian Equity Fund II, LP (“CEF 2”) that it advised to the advantage of Corinthian and three of its principals. First, Corinthian failed to apply a $1.2 million fee offset due to CEF 2. Second, Corinthian improperly used CEF 2 assets to fund its advisory operations. Third, Corinthian caused CEF 2 to overpay approximately $600,000 in organizational expenses. In his role as CFO, Tahan transferred these funds, documented the transfers, accounted for fees and expenses, and participated in the analysis and discussion that resulted in the transactions. Van Raalte failed to adequately supervise Tahan. As a result of this conduct, Corinthian violated Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-8 thereunder and Tahan caused Corinthian’s violations of these laws. In 2015, Corinthian’s former auditor discovered its failure to apply the fee offset and the excess expenses it charged CEF 2. By year-end 2015, Corinthian repaid the fee offset and reimbursed the expenses to CEF 2 in full with interest. In addition, Corinthian failed to issue audited financial statements for CEF 2 until more than 120 days after the fiscal years ended December 31, 2013, 2014 and 2015 and otherwise failed to comply with Section 206(4) of the Advisers Act and Rule 206(4)-2 (the “Custody Rule”) thereunder. Finally, Corinthian failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. As a result of this conduct, Corinthian violated Sections 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. Corinthian Capital Group agreed to pay a $100,000 penalty, Raalte agreed to a $25,000 penalty, and Tahan agreed to pay a $15,000 penalty.