The SEC charged a real estate developer and 27 real estate companies he operated with misleading investors about how their funds would be used. According to the SEC’s order, from January 2018 through at least May 2023, the defendants raised at least $34.4 million from approximately 100 outside investors by selling securities in companies created to invest in real estate. Defendants marketed each company as investing in a particular property or properties located in Washington, DC, Maryland, or Virginia. Investors that purchased the securities understood they were investing in specific real estate projects. In reality, the defendants failed to manage the companies separately, and routinely commingled investors’ money to cover shortfalls across related entities and to pay firm overhead expenses, such as salaries. The order noted that the firm commingled more than $50 million of property-specific funds during the relevant period despite concerns raised by business partners, internal and external bookkeeping staff, and other insiders. Defendants also failed to disclose the true and complete facts to investors who expressed concerns about the location and use of their money. The case highlights the risks and conflicts inherent when commingling assets and firms should expect scrutiny to the extent that they manage and control the assets of multiple funds or entities.