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Regulatory Sanctions

13 RIAs Nabbed for Not Filing Annual Reports

June 5, 2018

Thirteen registered investment advisers (“RIAs”) agreed to settle SEC charges that they repeatedly failed to file annual reports on Form PF. Private fund advisers managing $150 million or more of assets have been required to make annual filings on Form PF since 2012. 


The orders found that the 13 advisers named below were delinquent in their filings over multi-year periods. For example, Bachrach Asset Management failed to file Form PF and annual updates for 2012, 2013, 2014, 2015 and 2016. Each firm will pay a $75K penalty.


  • Bachrach Asset Management Inc.
  • Biglari Capital LLC
  • Brahma Management Ltd.
  • Bristol Group Inc.
  • CAI Managers & Co. L.P.
  • Cherokee Investment Partners LLC
  • Ecosystem Investment Partners LLC
  • Elm Partners Management LLC
  • HEP Management Corp.
  • Prescott General Partners LLC
  • RLJ Equity Partners LLC
  • Rose Park Advisors LLC
  • Veteri Place Corp.


The SEC uses Form PF data – which contains the amount of assets under management, fund strategy, performance, and use of borrowed money and derivatives - to monitor industry trends, inform rulemaking, identify compliance risks, and target examinations and enforcement investigations. 
The SEC publishes … quarterly reports with aggregated information and statistics derived from Form PF data to inform the public about the private fund industry. 
The SEC also provides Form PF data … to the Financial Stability Oversight Council to help it evaluate systemic risks posed by hedge funds and other private funds.