RECENT SEC ENFORCEMENT ACTIONS -

FEES AND EXPENSE ALLOCATIONS -

ECP Manager (Sept. 27, 2019) Administrative Proceeding File No. 3-19535 -

- A PE adviser settled claims which alleged that it caused its fund to overpay management fees three times, for a total of $102,304, by failing to exclude from the management fee calculation amounts attributable to certain written-off assets, despite the fund’s governing documents providing those amounts would be so excluded.

- The SEC ordered the adviser to pay disgorgement plus interest of $122,656 and $75,000 in penalty.