The SEC charged registered investment adviser (RIA), Touradji Capital Management LP, and its sole owner for failing to withdraw its registration notwithstanding the firm having less than $90 million in regulatory assets under management (RAUM), thereby violating Section 203A of the Investment Advisers Act and Rule 203A-1 thereunder. The firm did not respond to requests for documents by the SEC Exam staff, thereby violating Section 204(a) of the Advisers Act. While the SEC can terminate the registration of an investment adviser that does not have requisite RAUM, it is important that RIAs effectively monitor their RAUM and promptly submit amendments to Form ADV when required. If an RIA is no longer eligible for SEC registration but continues to manage client assets, it will need to register with the appropriate state securities regulator, unless it meets and exemption from registration.