The SEC issued an Order Instituting Administrative Proceedings on September 23, 2009, pursuant to Section 203(f) of the Investment Advisers Act of 1940, Making Findings and Imposing Remedial Sanctions against Scott M. Ross, who was serving as the investment adviser for three funds. According to the SEC's order, Mr. Ross raised $10 million from 300 investors. Mr. Ross, however, also misappropriated money from two of the funds, took undisclosed commissions from another fund, and used one fund's investors' money to pay off another fund's investors. Mr. Ross admitted wrongdoing, and has been subject to a permanent injunction from violations of Sections 17(a)(1-3) of the Securities Act of 1933 and Section 10(b) of the Securities and Exchange Act of 1934. Although Mr. Ross did not admit or deny the allegations, he accepted that he is not permitted to have any association with an investment adviser.