On January 5, 2010, the SEC settled charges against Mary Beth Stevens for her role in the misappropriation of funds belonging to the clients of AA Capital Partners, Inc., a registered investment adviser. According to the SEC, between 2004 and 2006, Ms. Stevens aided and abetted AA Capital and its president, John Orecchio, in misappropriating more than $23 million of investor funds. The SEC found that, in May 2004, Mr. Orecchio approached Ms. Stevens and told her that he owed a significant amount of money to the IRS based on his ownership interest in one of AA Capital’s affiliated private equity funds and a failure by AA Capital’s auditors to timely file certain tax returns. At Mr. Orecchio’s direction, she withdrew over $600,000 from AA Capital’s client trust accounts, deposited the funds into AA Capital’s main operating bank account and then wired the money to Mr. Orecchio’s personal bank account. Other alleged violations include at least 20 separate disbursements to Mr. Orecchio between May 2004 and October 2005, totaling over $5.7 million, for the purported tax liability, including wiring funds directly to the bank accounts of two entities in which Mr. Orecchio had a personal interest, a Michigan horse farm and a company which managed a Detroit strip club. The SEC also found that Ms. Stevens falsified the account statements she sent to AA Capital’s clients in order to conceal the improper withdrawals. As a result of these actions, Ms. Stevens agreed to pay disgorgement of $79,583.50, prejudgment interest of $22,472.24 and civil penalties of $50,000.