In a litigated case, the SEC charged P/E Capital Investment Management Partners and its CEO, Eliseo Prisno, for fraudulent billing practices, charging more than $2.4 million in unauthorized, undisclosed, inflated, or unearned fees. In some cases, the firm allegedly circumvented the brokerage firm's requirement that clients directly authorize additional fees by logging into client accounts using the client's credentials and routing multifactor authentication texts to a phone number they controlled. While the firm disclosed advisory fees of 2-2.4% of assets under management in Form ADV, the SEC alleged that it charged clients an average of more than 7%. The SEC further alleged that Prisno registered Ashtree with the SEC as an “internet adviser” hoping to attract and retain investors and clients. Prisno filed a Form ADV for Ashtree, claiming it had $5 million in assets under management and 94 clients. The SEC alleged that Prisno did so despite knowing that Ashtree was not operational, had zero clients, and zero assets under management. Even after SEC staff told Prisno that Ashtree was not eligible to register as an “internet adviser,” Prisno did not immediately withdraw Ashtree’s registration. Only after SEC staff told Prisno that it would be withdrawing Ashtree’s registration did he do so on his own initiative.