Undisclosed Conflicts Based on Relationship with Portfolio Company CEO (12/20/24)

The SEC charged private fund manager, Rose Park Advisors, LLC, and its owner Matthew Q. Christensen for failing to disclose actual or potential conflicts of interest based on Christensen’s familiar and financial connections with the Chief Executive Officer (CEO) on one of the portfolio companies in which one fund invested. The defendants agreed to $550,000 and $50,000 penalties, respectively in the settled action. This case serves as a reminder that the SEC expects that all actual and potential conflicts of interest related to investments be disclosed to clients and fund investors in advance of the investment.