Securities Regulation Daily Wrap Up, FRAUD AND MANIPULATION—Investment adviser receives industry bar for misappropriating millions in investor funds, (Aug 14, 2026)

By John Filar Atwood

The fund profited from an investment in pre-IPO shares of Palantir Technologies, but the adviser directed much of that money to himself.

A California-based investment adviser has agreed to an industry bar and other penalties to settle charges that he defrauded investors in a fund that invested in pre-IPO shares of Palantir Technologies. The SEC charged the adviser with transferring $2.91 million in fund profits to his personal account, well above the amount he was entitled to under the agreements with investors. The adviser agreed to settle without admitting or denying the charges and will pay disgorgement and a civil penalty (In the Matter of Ivan Moad, Release No. 34-106132 (August 13, 2026)).

The SEC stated that the adviser raised $1.26 million from at least 17 investors between February 2019 and September 2020, and used the funds to purchase pre-IPO Palantir shares. He provided investors with an operating agreement which disclosed that the adviser would receive 20 percent ownership of the investment fund, which entitled him to 20 percent of any profits.

In September 2020, the adviser purchased the pre-IPO Palantir shares at an average price of $6.94 per share. Palantir went public in late September, and the value of its shares increased significantly.

Significant profit. The adviser sold some of the fund’s Palantir shares at a significant profit and transferred the proceeds of the sales to the fund. He then used some of the funds to pay investor redemptions but also transferred funds to his personal account in accordance with the investor operating agreement.

The SEC claimed that the adviser transferred to his personal account at least $2.91 million, exceeding the profits to which he was entitled under the terms of the operating agreement. In all, the adviser misappropriated over $2.1 million after accounting for the amounts to which he was entitled and amounts he returned to investors, according to the SEC.

The SEC staff noted that prior to the Commission’s investigation, the adviser repaid certain clients based on a share price of $40, but to date has only been able to repay a fraction of what he misappropriated. Further, he repaid investors selectively, instead of pro rata, by repaying several investors their principal and appreciation to the $40 per share level while not paying the remaining investors anything, the SEC said.

Violations. The SEC charged the adviser with violating 1933 Act Section 17(a)(1), 1934 Act Section 10(b) and Rule 10b-5(a) and (c), and Investment Company Act Sections 206(1), 206(2), and 206(4).

The adviser agreed to the entry of a cease-and-desist order and a bar preventing him from association with any investment adviser, broker, dealer, municipal securities dealer, municipal advisor, transfer agent, or nationally recognized statistical rating organization. He also is prohibited from serving as an employee, officer, director, member of an advisory board, investment adviser or depositor of, or principal underwriter for, a registered investment company. He agreed to pay disgorgement of $2.06 million, prejudgment interest of $700,120, and a civil penalty of $236,451.

Companies: Palantir Technologies, Inc.

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