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One Minute Memo: Private Equity Group and Former Senior Executive Charged by the SEC for Using Unregistered Broker Dealer: Implications for Private Funds and Other Issuers and Their Investors -
On March 11, 2013, the Securities and Exchange Commission ("SEC") announced charges against New York-based private equity firm Ranieri Partners, a former senior executive, Donald W. Phillips ("Phillips"), and an unregistered broker, William M. Stephens ("Stephens"), in connection with the solicitation of more than $500 million in capital commitments for private funds managed by the firm. The SEC's orders found that Phillips had aided and abetted the unregistered broker's violations by providing him with key fund documents and information and ignoring red flags indicating that Stephens had gone beyond the limited role of a finder.

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http://www.seyfarth.com/publications/OMM032013

http://www.ilw.com/seminars/jennifermoseleycitation1.pdf http://www.ilw.com/seminars/jennifermoseleycitation2.pdf

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