Black Hill Capital Partners, Llc

Allegations: THE FIRM FAILED TO PERFORM AN ANNUAL INDEPENDENT AUDIT OF A POOLED INVESTMENT VEHICLE OF WHICH IT HAD CUSTODY. ADDITIONALLY, THE FIRM AND AN AFFILIATE OF THE FIRM BORROWED CLIENT ASSETS FROM THE POOLED INVESTMENT VEHICLE. Status: Final Sanction Detail: A FINE OF $50,000 WAS LEVIED AGAINST BLACK HILL CAPITAL AND AN ADVISORY AFFILIATE. NO PORTION HAS BEEN WAIVED. PURSUANT TO THE TERMS OF THE CONSENT ORDER, THE FULL AMOUNT OF $50,000 OF THE FINE HAS BEEN PAID. $20,000 WAS PAID IN OCTOBER 2021, $20,000 WAS PAID IN FEBRUARY 2022, AND $10,000 WAS PAID IN JUNE 2022. Summary: THE FIRM FAILED TO PERFORM AN ANNUAL INDEPENDENT AUDIT OF A POOLED INVESTMENT VEHICLE OF WHICH IT HAD CUSTODY. ADDITIONALLY, THE FIRM (AND AN AFFILIATE OF THE FIRM) BORROWED CLIENT ASSETS FROM THE POOLED INVESTMENT VEHICLE. THE FIRM FILED A FORM ADV-W IN DECEMBER 2020 TO WITHDRAW ITS REGISTRATION AS A CALIFORNIA REGISTERED INVESTMENT ADVISER, BUT THE COMMISSIONER ISSUED AN ORDER IMPOSING CONDITIONS TO POSTPONE THE WITHDRAWAL UNTIL AN ONGOING INVESTIGATION OF BLACK HILL WAS COMPLETED. UPON CONCLUSION OF THE INVESTIGATION IN SEPTEMBER 2021, THE COMMISSIONER AND BLACK HILL ENTERED INTO A CONSENT ORDER THAT ORDERED BLACK HILL AND THE ADVISORY AFFILIATE TO CEASE AND DESIST VIOLATING CALIFORNIA CORPORATIONS CODE SECTIONS 25235 AND 25238, AND 10 CCR SECTIONS 260, 237, SUBDIVISION (A) AND 260.238, SUBDIVISION (F), IMPOSED A PENALTY IN THE AMOUNT OF $50,000 TO BE PAID IN FULL BY JUNE 23, 2022, AND REVOKED THE FIRM'S CALIFORNIA INVESTMENT ADVISER CERTIFICATE. THE FIRM AND ADVISORY AFFILIATE CONSENTED TO THE TERMS.