Instead of crediting the $1.26 million 100% against management fees, “Global miscalculated the offset and only credited Fund III limited partners a portion of these director fees. Global has reviewed the director fees it collected from the portfolio company investment, recalculated the correct management fee offset and amount, and voluntarily remediated Fund III limited partners in the amount of $674,362, plus interest,” the agency added.
The SEC said it considered “remedial acts promptly undertaken by Global, including voluntary remediation of the relevant advisory fees, enhanced fund disclosures and improved procedures and controls” around fee offsets in its decision to accept Global’s settlement offer.
The receptionist answering the phone at Global’s headquarters said that all managers were out for the holiday. There was no comment from the company by deadline. Global has no other prior disciplinary history with the SEC.