The SEC charged a real estate private fund manager, Colony Capital Investment Advisors, LLC, for failing to obtain LPAC or LP consent for agreements with affiliated service providers to provide services including fund-level administrative fees, asset-level services, such as loan servicing, property maintenance, and property-level accounting. The SEC noted that while the funds’ audited financial statements did disclose the existence of such agreements and the expenses paid to affiliates pursuant to such agreements, such disclosure was not made until after the agreements had been entered into and expenses incurred. The firm was further faulted for failing to adopt or implement policies and procedures in connection with the use of affiliated service providers for reviewing and approving agreements and determining the arm’s-length nature of transactions. The firm voluntarily reimbursed certain expenses and paid a $350,000 penalty.