Corinthian Capital Group, LLC

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of
Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution
Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives
rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD Number:
160346
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CORINTHIAN CAPITAL GROUP, LLC
(For individuals, Last, First, Middle)
CRD Number:
6026999
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
VAN RAALTE, PETER, BAIRD
(For individuals, Last, First, Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for
registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event
occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years
ago.

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the
event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CIVIL PENALTY AND CENSURE
3.
Date Initiated (MM/DD/YYYY): 
05/06/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ADMINISTRATIVE PROCEEDING FILE NO. 3-19159
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Direct Investment(s) - DPP & LP Interest(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE ORDER ENTERED ON MAY 6, 2019 ALLEGED THAT IN 2014 AND 2015, CORINTHIAN MISUSED THE ASSETS IN A PRIVATE EQUITY FUND, CORINTHIAN EQUITY FUND II, LP ("CEF
2") BY FAILING TO APPLY A FEE OFFSET DUE TO CEF 2, IMPROPERLY USING CEF 2 ASSETS TO FUND ITS ADVISORY OPERATIONS, AND CAUSING CEF 2 TO OVERPAY
APPROXIMATELY CERTAIN ORGANIZATIONAL EXPENSES. PURSUANT TO AN OFFER OF SETTLEMENT, THE SEC FOUND, AND THE RESPONDENTS NEITHER ADMITTED NOR DENIED,
THAT CORINTHIAN VIOLATED SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-8 THEREUNDER AND THAT DAVID TAHAN, CORINTHIAN'S FORMER CFO,
CAUSED CORINTHIAN'S VIOLATIONS OF THESE LAWS, THAT CORINTHIAN'S CEO, PETER VAN RAALTE, FAILED REASONABLY TO SUPERVISE THE FORMER CFO WITHIN THE
MEANING OF SECTION 203(E)(6) OF THE ADVISERS ACT, THAT CORINTHIAN FAILED TO COMPLY WITH SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-2 (THE
"CUSTODY RULE") DUE TO ITS FAILURE TO TIMELY DELIVER CERTAIN AUDITED FINANCIAL STATEMENTS FOR 2013, 2014 AND 2015, AND THAT CORINTHIAN FAILED TO ADOPT
AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT IN VIOLATION OF SECTIONS 206(4) OF THE
ADVISERS ACT AND RULE 206(4)-7 THEREUNDER.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Other
11. Resolution Date (MM/DD/YYYY):
05/06/2019
 Exact
 Explanation
If not exact, provide explanation:
ORDER AND OFFER OF SETTLEMENT
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 100,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction

 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal,
etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition
has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an
advisory affiliate, date paid and if any portion of penalty was waived: 
THE ORDER IMPOSED A CIVIL MONETARY PENALTY OF $100,000 AND A CENSURE ON CORINTHIAN, AND A CIVIL MONETARY PENALTY OF $25,000 ON MR. VAN RAALTE.
PAYMENT IS TO BE MADE IN THE FOLLOWING INSTALLMENTS. CORINTHIAN: (1) $40,000 WITHIN 10 DAYS OF THE ENTRY OF THE ORDER; (2) 30,000 WITHIN 6 MONTHS OF
THE ENTRY OF THE ORDER; AND $30,000 WITHIN 12 MONTHS OF THE ORDER. MR. VAN RAALTE: (1) $10,000 WITHIN 10 DAYS OF THE ENTRY OF THE ORDER; (2) 7,500
WITHIN 6 MONTHS OF THE ENTRY OF THE ORDER; AND $7,500 WITHIN 12 MONTHS OF THE ORDER. THE FIRST INSTALLMENTS WERE PAID DURING THE WEEK OF MAY 6,
2019.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space
provided).
THE SEC ADMINISTRATIVE ORDER IS FINAL. THE SEC CONSIDERED THE REMEDIAL ACTS AND COOPERATION EFFORTS BY CORINTHIAN IN DETERMINING TO ACCEPT THE OFFER
OF SETTLEMENT. AS NOTED IN THE ORDER, BY YEAR-END 2015, CORINTHIAN REPAID THE FEE OFFSET AND REIMBURSED THE RELEVANT EXPENSES TO CEF 2 IN FULL WITH
INTEREST.