Assets under management Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Private Funds
Private funds reported by Pinegrove Venture Partners, LLC
Employee Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.
Ownership
Reported direct and indirect ownership ranges
Reported ownership ranges
Highlighted bands show the percentage range reported in Form ADV.
Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Pinegrove Venture Partners, LLC.
Reported ownership and control details
Form ADV · Filing date 2026-06-01 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | PVP MIDDLE HOLDCO, LLCMANAGING MEMBERDomestic entity | PINEGROVE VENTURE PARTNERS, LLC | 75% or moreCode E | Yes | MANAGING MEMBER04/2023 | Schedule APDF page 387 |
| 2 | BEAU DANIEL LASKEYMANAGING PARTNERIndividual | PINEGROVE VENTURE PARTNERS, LLC | Less than 5%Code NA | Yes | MANAGING PARTNER01/2024 | Schedule APDF page 387 |
| 3 | SULAIMAN SADRUDIN MANDANIMANAGING PARTNERIndividual | PINEGROVE VENTURE PARTNERS, LLC | Less than 5%Code NA | Yes | MANAGING PARTNER01/2024 | Schedule APDF page 387 |
| 4 | AARON GARTH GERSHENBERGCEOIndividual | PINEGROVE VENTURE PARTNERS, LLC | Less than 5%Code NA | Yes | CEO09/2024 | Schedule APDF page 387 |
| 5 | JILLANA JODELL DOWNINGCHIEF COMPLIANCE OFFICERIndividual | PINEGROVE VENTURE PARTNERS, LLC | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER10/2024 | Schedule APDF page 387 |
| 6 | E-JOHN NMN LEECHIEF OPERATING OFFICERIndividual | PINEGROVE VENTURE PARTNERS, LLC | Less than 5%Code NA | Yes | CHIEF OPERATING OFFICER09/2025 | Schedule APDF page 387 |
| 7 | JAMES ELLIS ELLISONMANAGING PARTNERIndividual | PINEGROVE VENTURE PARTNERS, LLC | Less than 5%Code NA | Yes | MANAGING PARTNER01/2024 | Schedule APDF page 388 |
| 8 | Thorben HettMANAGING PARTNERIndividual | PINEGROVE VENTURE PARTNERS, LLC | Less than 5%Code NA | Yes | MANAGING PARTNER01/2025 | Schedule APDF page 388 |
| 9 | PINEGROVE SIERRA HOLDCO LLCMANAGING MEMBERDomestic entity | PVP MIDDLE HOLDCO, LLC | 75% or moreCode E | Yes | MANAGING MEMBER09/2024 | Schedule BPDF page 388 |
| 10 | BRIAN KEITH LAIBOWBOARD MEMBERIndividual | PINEGROVE SIERRA HOLDCO LLC | Percentage not specifiedCode F | Yes | BOARD MEMBER09/2024 | Schedule BPDF page 388 |
| 11 | ANUJ RANJANBOARD MEMBERIndividual | PINEGROVE SIERRA HOLDCO LLC | Percentage not specifiedCode F | Yes | BOARD MEMBER09/2024 | Schedule BPDF page 388 |
| 12 | MARK SRULOWITZBOARD MEMBERIndividual | PINEGROVE SIERRA HOLDCO LLC | Percentage not specifiedCode F | Yes | BOARD MEMBER09/2024 | Schedule BPDF page 388 |
| 13 | KEVIN ANTHONY KELLYBOARD MEMBERIndividual | PINEGROVE SIERRA HOLDCO LLC | Percentage not specifiedCode F | Yes | BOARD MEMBER09/2024 | Schedule BPDF page 388 |
| 14 | KEITH BRYON JOHNSONBOARD MEMBERIndividual | PINEGROVE SIERRA HOLDCO LLC | Percentage not specifiedCode F | Yes | BOARD MEMBER09/2024 | Schedule BPDF page 388 |
| 15 | BROOKFIELD SIERRA HOLDCO LLCMEMBERDomestic entity | PINEGROVE SIERRA HOLDCO LLC | 25% to less than 50%Code C | Yes | MEMBER04/2024 | Schedule BPDF page 388 |
| 16 | BROOKFIELD US INC.MEMBERDomestic entity | BROOKFIELD SIERRA HOLDCO LLC | 75% or moreCode E | Yes | MEMBER04/2024 | Schedule BPDF page 388 |
| 17 | BROOKFIELD US HOLDINGS INC.SHAREHOLDERForeign entity | BROOKFIELD US INC. | 75% or moreCode E | Yes | SHAREHOLDER01/2003 | Schedule BPDF page 388 |
| 18 | BROOKFIELD ASSET MANAGEMENT ULCSHAREHOLDERForeign entity | BROOKFIELD US HOLDINGS INC. | 75% or moreCode E | Yes | SHAREHOLDER12/2022 | Schedule BPDF page 388 |
| 19 | BROOKFIELD ASSET MANAGEMENT LTDSHAREHOLDERForeign entity | BROOKFIELD ASSET MANAGEMENT ULC | 25% to less than 50%Code C | Yes | SHAREHOLDER12/2022 | Schedule BPDF page 388 |
| 20 | BROOKFIELD CORPORATIONSHAREHOLDERForeign entity | BROOKFIELD ASSET MANAGEMENT ULC | 75% or moreCode E | Yes | SHAREHOLDER12/2022 | Schedule BPDF page 388 |
| 21 | SCHF (M) PV, L.P.MEMBERDomestic entity | PINEGROVE SIERRA HOLDCO LLC | 25% to less than 50%Code C | Yes | MEMBER05/2024 | Schedule BPDF page 388 |
| 22 | SCHF US, L.P.LIMITED PARTNERDomestic entity | SCHF (M) PV, L.P. | 50% to less than 75%Code D | No | LIMITED PARTNER06/2010 | Schedule BPDF page 388 |
| 23 | SCHF (GPE), LLCGENERAL PARTNERDomestic entity | SCHF (M) PV, L.P. | Percentage not specifiedCode F | Yes | GENERAL PARTNER03/2010 | Schedule BPDF page 388 |
| 24 | MONTAGUE ISLAND LLCMEMBERDomestic entity | SCHF (GPE), LLC | 25% to less than 50%Code C | Yes | MEMBER12/2020 | Schedule BPDF page 388 |
| 25 | PORT ORFORD TRUSTMEMBERDomestic entity | MONTAGUE ISLAND LLC | 75% or moreCode E | Yes | MEMBER12/2020 | Schedule BPDF page 389 |
| 26 | ALSACE ONEIDA, LLCMEMBERDomestic entity | SCHF (GPE), LLC | 25% to less than 50%Code C | Yes | MEMBER12/2020 | Schedule BPDF page 389 |
| 27 | Michelle Jodi WachsMEMBERIndividual | ALSACE ONEIDA, LLC | Percentage not specifiedCode F | Yes | MEMBER11/2020 | Schedule BPDF page 389 |
| 28 | MICHELLE J WACHS 2020 IRREOVCABLE TRUSTMEMBERDomestic entity | ALSACE ONEIDA, LLC | 25% to less than 50%Code C | No | MEMBER12/2020 | Schedule BPDF page 389 |
| 29 | IRWIN R. GROSS 2020 IRREVOCABLE TRUSTMEMBERDomestic entity | ALSACE ONEIDA, LLC | 25% to less than 50%Code C | No | MEMBER12/2020 | Schedule BPDF page 389 |
| 30 | IRWIN ROBERT GROSSMEMBERIndividual | ALSACE ONEIDA, LLC | Percentage not specifiedCode F | Yes | MEMBER11/2020 | Schedule BPDF page 389 |
| 31 | IRWIN ROBERT GROSSTRUSTEEIndividual | IRWIN R. GROSS 2020 IRREVOCABLE TRUST | Percentage not specifiedCode F | Yes | TRUSTEE11/2020 | Schedule BPDF page 389 |
| 32 | Michelle Jodi WachsTRUSTEEIndividual | MICHELLE J WACHS 2020 IRREOVCABLE TRUST | Percentage not specifiedCode F | Yes | TRUSTEE11/2020 | Schedule BPDF page 389 |
| 33 | Betsy Andrews JohnsonTRUSTEEIndividual | PORT ORFORD TRUST | Percentage not specifiedCode F | Yes | TRUSTEE12/2020 | Schedule BPDF page 389 |
Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.
Compliance & Disclosures
Filing dated 6/1/2026 6:59:16 PM
Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.
AFelonies2 No
In the past ten years, have you or any advisory affiliate:
- A1Been convicted of or pleaded guilty or no contest to a felony?No
- A2Been charged with a felony?No
BMisdemeanors2 No
In the past ten years, have you or any advisory affiliate:
- B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
- B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions5 No
Has the SEC or CFTC ever:
- C1Found you or an advisory affiliate made a false statement or omission?No
- C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?No
- C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- C4Entered an order against you or an advisory affiliate in connection with investment-related activity?No
- C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?No
DOther regulatory actions4 Yes1 No
Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:
- D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
- D2Found you or an advisory affiliate violated investment-related regulations or statutes?Yes
- D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?Yes
- D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
- D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?Yes
ESelf-regulatory organization actions4 No
Has a self-regulatory organization or commodities exchange ever:
- E1Found you or an advisory affiliate made a false statement or omission?No
- E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?No
- E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
- FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
- GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No
(1) Court actions
Has a domestic or foreign court:
- H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
- H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
- H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No
(2) Pending civil proceedings
- H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 2 source blocks
Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.
regulatory · block 1SVB INNOVATION CREDIT FUND VIII, L.P.PDF pages 389–391
- Advisory affiliate name — filed text
- SVB INNOVATION CREDIT FUND VIII, L.P.
- Regulator name — filed text
- CALIFORNIA DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION
- Monetary/Fine Amount — filed text
- $ 14,500.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
THE CONSENT ORDER CONSTITUTED A FULL AND FINAL RESOLUTION OF THE ISSUE. NO FURTHER PROCEEDINGS OR ACTIONS ARE ONGOING.
Other filed details
Description of allegations — filed text
AS A RESULT OF AN ACQUISITION TRANSACTION THAT OCCURRED ON DECEMBER 23, 2020, THE CONTROL AND MANAGEMENT OF SVB INNOVATION CREDIT FUND VIII, L.P. ("FUND VIII") WAS CHANGED TO A NEW (AND CURRENT) GENERAL PARTNER, SVB INNOVATION CREDIT PARTNERS VIII, LLC. NOTE THAT, UPON THE CHANGE OF CONTROL, NOTICE TO THE CALIFORNIA DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION (DFPI) WAS INITIATED TO CHANGE FUND VIII'S ADDRESS, NAME, CONTACT INFORMATION, AND OTHER MANAGEMENT INFORMATION. THESE CHANGES WERE APPROVED BY THE DFPI ON OR ABOUT JUNE 4, 2021. UNFORTUNATELY, FUND VIII INADVERTENTLY MISSED THE DEADLINE TO FILE ITS ANNUAL REPORT WITH THE DFPI BY MARCH 15, 2021, AS REQUIRED BY CALIFORNIA FINANCIAL CODE 22159. THIS WAS PARTIALLY DUE TO FUND VIII NOT RECEIVING NOTICES SENT BY THE DFPI TO CFL LICENSEES BETWEEN DECEMBER 2020 AND MARCH 2021 SINCE THE DFPI HAD NOT YET COMPLETED THE PROCESS TO CHANGE FUND VIII'S CONTACT AND OTHER INFORMATION AS MENTIONED ABOVE. ON APRIL 16, 2021, THE DFPI COMMISSIONER ISSUED AN ORDER SUMMARILY REVOKING CALIFORNIA FINANCE LENDERS LICENSE PURSUANT TO FINANCIAL CODE SECTION 22715 FOR CFL LICENSE NUMBER 60DBO- 65349 ("SUMMARY REVOCATION ORDER"). ON APRIL 29, 2021, FUND VIII BECAME AWARE OF THE SUMMARY REVOCATION ORDER, AND ON APRIL 30, 2021, FUND VIII SUBMITTED ITS ANNUAL REPORT TO THE DFPI. ON MAY 6, 2021, THE DFPI COMMISSIONER AND FUND VIII ENTERED INTO A CONSENT ORDER THAT RESCINDED THE SUMMARY REVOCATION ORDER THEREBY REINSTATING FUND VIII'S CFL LICENSE. FUND VIII IS CURRENTLY MANAGED BY THE INVESTMENT ADVISER.
Sanction detail — filed text
MONETARY PENALTY IN THE AMOUNT OF $14,500 PAID ON MAY 12, 2021.
Full extracted filing text
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:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
SVB INNOVATION CREDIT
FUND VIII, L.P.
(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)
CALIFORNIA DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION
2.
Principal Sanction:
Revocation
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
04/16/2021
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CFL # 60DBO-65349
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Debt - Corporate
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
AS A RESULT OF AN ACQUISITION TRANSACTION THAT OCCURRED ON DECEMBER 23, 2020, THE CONTROL AND MANAGEMENT OF SVB INNOVATION
CREDIT FUND VIII, L.P. ("FUND VIII") WAS CHANGED TO A NEW (AND CURRENT) GENERAL PARTNER, SVB INNOVATION CREDIT PARTNERS VIII, LLC.
NOTE THAT, UPON THE CHANGE OF CONTROL, NOTICE TO THE CALIFORNIA DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION (DFPI) WAS
INITIATED TO CHANGE FUND VIII'S ADDRESS, NAME, CONTACT INFORMATION, AND OTHER MANAGEMENT INFORMATION. THESE CHANGES WERE
APPROVED BY THE DFPI ON OR ABOUT JUNE 4, 2021. UNFORTUNATELY, FUND VIII INADVERTENTLY MISSED THE DEADLINE TO FILE ITS ANNUAL REPORT
WITH THE DFPI BY MARCH 15, 2021, AS REQUIRED BY CALIFORNIA FINANCIAL CODE 22159. THIS WAS PARTIALLY DUE TO FUND VIII NOT RECEIVING
NOTICES SENT BY THE DFPI TO CFL LICENSEES BETWEEN DECEMBER 2020 AND MARCH 2021 SINCE THE DFPI HAD NOT YET COMPLETED THE PROCESS
TO CHANGE FUND VIII'S CONTACT AND OTHER INFORMATION AS MENTIONED ABOVE. ON APRIL 16, 2021, THE DFPI COMMISSIONER ISSUED AN ORDER
SUMMARILY REVOKING CALIFORNIA FINANCE LENDERS LICENSE PURSUANT TO FINANCIAL CODE SECTION 22715 FOR CFL LICENSE NUMBER 60DBO-
65349 ("SUMMARY REVOCATION ORDER"). ON APRIL 29, 2021, FUND VIII BECAME AWARE OF THE SUMMARY REVOCATION ORDER, AND ON APRIL 30,
2021, FUND VIII SUBMITTED ITS ANNUAL REPORT TO THE DFPI. ON MAY 6, 2021, THE DFPI COMMISSIONER AND FUND VIII ENTERED INTO A CONSENT
ORDER THAT RESCINDED THE SUMMARY REVOCATION ORDER THEREBY REINSTATING FUND VIII'S CFL LICENSE. FUND VIII IS CURRENTLY MANAGED BY
THE INVESTMENT ADVISER.
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:
Order
11. Resolution Date (MM/DD/YYYY):
05/06/2021
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 14,500.00
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:
MONETARY PENALTY IN THE AMOUNT OF $14,500 PAID ON MAY 12, 2021.
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 CONSENT ORDER CONSTITUTED A FULL AND FINAL RESOLUTION OF THE ISSUE. NO FURTHER PROCEEDINGS OR ACTIONS ARE ONGOING.regulatory · block 2PDF pages 391–393
- Regulator name — filed text
- SECURITIES AND EXCHANGE BOARD OF INDIA (SEBI)
- Monetary/Fine Amount — filed text
- $ 114,865.00
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
ON MARCH 19, 2021, THE NOTICEES RECEIVED A NOTICE FROM SEBI ALLEGING THAT THE NOTICEES ACCEPTED IMPERMISSIBLY SMALL INVESTMENTS FROM CERTAIN INVESTORS IN THE FUND, FAILED TO MAINTAIN SUFFICIENTLY LARGE INVESTMENTS THEMSELVES IN THE FUND, AND EXTENDED THE TENURE OF THE FUND BEYOND THE PERMISSIBLE PERIOD, IN VIOLATION OF THE SEBI ACT. THE NOTICE FURTHER ALLEGED THAT THE ANNUAL COMPLIANCE TEST REPORT FOR THE FUND DID NOT REFLECT THE NON-COMPLIANCES ASSOCIATED WITH THE ALLEGED VIOLATIONS. IN ORDER TO FULLY SETTLE THE PROCEEDING, THE NOTICEES AGREED TO PAY INR 8,500,000, OR APPROXIMATELY USD $114,865, WHICH WAS TIMELY PAID WITHOUT AN ADMISSION OR DENIAL OF GUILT.
Other filed details
Description of allegations — filed text
THE SECURITIES AND EXCHANGE BOARD OF INDIA ("SEBI") ALLEGED THAT: (1) PENBROOK CAPITAL ADVISORS PRIVATE LIMITED ("PENBROOK"), THE INVESTMENT MANAGER OF PENINSULA BROOKFIELD INDIA REAL ESTATE FUND (THE "FUND") AND A JOINT VENTURE BETWEEN (I) BROOKFIELD CAPITAL PARTNERS LTD (BERMUDA), A WHOLLY OWNED SUBSIDIARY OF BROOKFIELD ASSET MANAGEMENT INC., AND (II) PENINSULA LAND LTD, A THIRD-PARTY REAL ESTATE DEVELOPER); (2) THE CURRENT AND FORMER DIRECTORS OF PENBROOK, INCLUDING ANUJ RANJAN (FORMER DIRECTOR) AND SRIDHAR RENGAN (CURRENT DIRECTOR); AND (3) PENINSULA BROOKFIELD TRUSTEE PRIVATE LIMITED, (THE TRUSTEE OF THE FUND, HAVING THE SAME SHAREHOLDERS AS PENBROOK) ((1), (2) AND (3) COLLECTIVELY, THE "NOTICEES"), ACCEPTED IMPERMISSIBLY SMALL INVESTMENTS FROM CERTAIN INVESTORS IN THE FUND, FAILED TO MAINTAIN SUFFICIENTLY LARGE INVESTMENTS THEMSELVES IN THE FUND, AND EXTENDED THE TENURE OF THE FUND BEYOND THE PERMISSIBLE PERIOD, IN VIOLATION OF THE SECURITIES AND EXCHANGE BOARD OF INDIA ACT OF 1922 AND REGULATIONS FRAMED THEREUNDER (THE "SEBI ACT"). SEBI FURTHER ALLEGED THAT THE ANNUAL COMPLIANCE TEST REPORT FOR THE FUND DID NOT REFLECT THE NON-COMPLIANCE MATTERS ASSOCIATED WITH THE ALLEGED VIOLATIONS.
Sanction detail — filed text
THE NOTICEES AGREED TO A TOTAL SETTLEMENT AMOUNT OF INR 8,500,000, OR APPROXIMATELY USD $114,865, WHICH WAS TIMELY PAID WITHOUT AN ADMISSION OR DENIAL OF GUILT.
Full extracted filing text
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:
7719006
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
rengan, sridhar
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
PENBROOK CAPITAL ADVISORS
PRIVATE LIMITED
(For individuals, Last, First,
Middle)
CRD
Number:
7358778
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
RANJAN, ANUJ
(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)
SECURITIES AND EXCHANGE BOARD OF INDIA (SEBI)
2.
Principal Sanction:
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
03/19/2021
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
SO/MC/HP/2021-22/6448-49 AND SO/MC/HP/2021-22/6451-57.
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 SECURITIES AND EXCHANGE BOARD OF INDIA ("SEBI") ALLEGED THAT: (1) PENBROOK CAPITAL ADVISORS PRIVATE LIMITED ("PENBROOK"), THE
INVESTMENT MANAGER OF PENINSULA BROOKFIELD INDIA REAL ESTATE FUND (THE "FUND") AND A JOINT VENTURE BETWEEN (I) BROOKFIELD CAPITAL
PARTNERS LTD (BERMUDA), A WHOLLY OWNED SUBSIDIARY OF BROOKFIELD ASSET MANAGEMENT INC., AND (II) PENINSULA LAND LTD, A THIRD-PARTY
REAL ESTATE DEVELOPER); (2) THE CURRENT AND FORMER DIRECTORS OF PENBROOK, INCLUDING ANUJ RANJAN (FORMER DIRECTOR) AND SRIDHAR
RENGAN (CURRENT DIRECTOR); AND (3) PENINSULA BROOKFIELD TRUSTEE PRIVATE LIMITED, (THE TRUSTEE OF THE FUND, HAVING THE SAME
SHAREHOLDERS AS PENBROOK) ((1), (2) AND (3) COLLECTIVELY, THE "NOTICEES"), ACCEPTED IMPERMISSIBLY SMALL INVESTMENTS FROM CERTAIN
INVESTORS IN THE FUND, FAILED TO MAINTAIN SUFFICIENTLY LARGE INVESTMENTS THEMSELVES IN THE FUND, AND EXTENDED THE TENURE OF THE
FUND BEYOND THE PERMISSIBLE PERIOD, IN VIOLATION OF THE SECURITIES AND EXCHANGE BOARD OF INDIA ACT OF 1922 AND REGULATIONS
FRAMED THEREUNDER (THE "SEBI ACT"). SEBI FURTHER ALLEGED THAT THE ANNUAL COMPLIANCE TEST REPORT FOR THE FUND DID NOT REFLECT THE
NON-COMPLIANCE MATTERS ASSOCIATED WITH THE ALLEGED VIOLATIONS.
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:
Settled
11. Resolution Date (MM/DD/YYYY):
01/28/2022
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 114,865.00
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 NOTICEES AGREED TO A TOTAL SETTLEMENT AMOUNT OF INR 8,500,000, OR APPROXIMATELY USD $114,865, WHICH WAS TIMELY PAID
WITHOUT AN ADMISSION OR DENIAL OF GUILT.
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).
ON MARCH 19, 2021, THE NOTICEES RECEIVED A NOTICE FROM SEBI ALLEGING THAT THE NOTICEES ACCEPTED IMPERMISSIBLY SMALL INVESTMENTS
FROM CERTAIN INVESTORS IN THE FUND, FAILED TO MAINTAIN SUFFICIENTLY LARGE INVESTMENTS THEMSELVES IN THE FUND, AND EXTENDED THE
TENURE OF THE FUND BEYOND THE PERMISSIBLE PERIOD, IN VIOLATION OF THE SEBI ACT. THE NOTICE FURTHER ALLEGED THAT THE ANNUAL
COMPLIANCE TEST REPORT FOR THE FUND DID NOT REFLECT THE NON-COMPLIANCES ASSOCIATED WITH THE ALLEGED VIOLATIONS. IN ORDER TO
FULLY SETTLE THE PROCEEDING, THE NOTICEES AGREED TO PAY INR 8,500,000, OR APPROXIMATELY USD $114,865, WHICH WAS TIMELY PAID
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