The SEC has commenced enforcement proceedings against the portfolio manager of a private equity fund-of-funds for misleading investors about the fund’s returns.  The SEC charges that the respondent had primary responsibility for preparing marketing materials and that pitch books, RFIs, and other materials overstated the fund’s returns.  The SEC asserts that the respondent used a pitch book that showed internal rates of return without the effect of fees charged by both the fund-of-funds and the underlying funds.  The SEC also alleges that the respondent used his own valuation for one of the largest investments, which valuation was substantially greater than the NAV reported by the underlying fund.  The SEC contends that the respondent tried to circumvent comments made by compliance personnel.  The respondent’s firm already paid $2.8 Million to settle related charges (See http://www.sec.gov/litigation/admin/2013/33-9443.pdf