Forge Global Advisors Llc

Allegations: ON DECEMBER 6, 2016, THE SEC AND EQUIDATE, INC. (AS WELL AS ITS THEN WHOLLY OWNED SUBSIDIARY, EQUIDATE HOLDINGS LLC), AGREED TO SETTLE CHARGES THAT EQUIDATE, INC. AND EQUIDATE HOLDINGS LLC VIOLATED FEDERAL SECURITIES LAWS BY FAILING TO REGISTER SECURITY-BASED SWAPS THAT WERE OFFERED AND SOLD ONLINE TO SHAREHOLDERS IN PRE-IPO COMPANIES. THE SEC INSTITUTED AN ORDER FINDING THAT EQUIDATE, INC. AND EQUIDATE HOLDINGS LLC SOUGHT TO PROVIDE LIQUIDITY FOR EMPLOYEES OF PRIVATE, GROWTH-STAGE COMPANIES IN THE SILICON VALLEY AND OTHERS HOLDING RESTRICTED SHARES OF THEIR STOCK, AND ITS PLATFORM ESSENTIALLY MATCHED THESE SHAREHOLDERS WITH INVESTORS SEEKING TO INVEST IN THE POTENTIAL ECONOMIC RETURN ON THOSE SHARES. EQUIDATE, INC. CONDUCTED TRANSACTIONS THROUGH CONTRACTS THAT ITS SUBSIDIARY ENTERED INTO WITH THE SHAREHOLDERS AND INVESTORS, AND PAYMENT PROVISIONS WERE TRIGGERED BY SUCH EVENTS AS A MERGER, ACQUISITION, OR IPO AT THE UNDERLYING COMPANY. EQUIDATE, INC. AND EQUIDATE HOLDINGS, LLC, HOWEVER, NEVER FILED A REGISTRATION STATEMENT FOR THE SWAPS NOR SOLD THEM THROUGH A NATIONAL SECURITIES EXCHANGE (AS REQUIRED). EQUIDATE, INC. AND EQUIDATE HOLDINGS LLC CONSENTED TO THE SEC'S ORDER WITHOUT ADMITTING OR DENYING THE FINDINGS AND AGREED TO PAY AN $80,000 PENALTY. EQUIDATE, INC. STOPPED OFFERING AND SELLING SECURITY-BASED SWAPS IN DECEMBER 2015 AS A RESULT OF THE SEC INVESTIGATION. EQUIDATE, INC. CHANGED THE STRUCTURE OF ITS TRANSACTIONS IN THE FOURTH QUARTER OF 2015 TO THE FUND STRUCTURE DESCRIBED IN THE ADVISER'S FORM ADV PART 2A. Status: Final Sanction Detail: ON DECEMBER 6, 2016, THE SEC AND EQUIDATE, INC. (AS WELL AS ITS THEN WHOLLY OWNED SUBSIDIARY, EQUIDATE HOLDINGS LLC), AGREED TO SETTLE CHARGES THAT EQUIDATE, INC. AND EQUIDATE HOLDINGS LLC VIOLATED FEDERAL SECURITIES LAWS BY FAILING TO REGISTER SECURITY-BASED SWAPS THAT WERE OFFERED AND SOLD ONLINE TO SHAREHOLDERS IN PRE-IPO COMPANIES. THE SEC INSTITUTED AN ORDER FINDING THAT EQUIDATE, INC. AND EQUIDATE HOLDINGS LLC SOUGHT TO PROVIDE LIQUIDITY FOR EMPLOYEES OF PRIVATE, GROWTH-STAGE COMPANIES IN THE SILICON VALLEY AND OTHERS HOLDING RESTRICTED SHARES OF THEIR STOCK, AND ITS PLATFORM ESSENTIALLY MATCHED THESE SHAREHOLDERS WITH INVESTORS SEEKING TO INVEST IN THE POTENTIAL ECONOMIC RETURN ON THOSE SHARES. EQUIDATE, INC. CONDUCTED TRANSACTIONS THROUGH CONTRACTS THAT ITS SUBSIDIARY ENTERED INTO WITH THE SHAREHOLDERS AND INVESTORS, AND PAYMENT PROVISIONS WERE TRIGGERED BY SUCH EVENTS AS A MERGER, ACQUISITION, OR IPO AT THE UNDERLYING COMPANY. EQUIDATE, INC. AND EQUIDATE HOLDINGS, LLC, HOWEVER, NEVER FILED A REGISTRATION STATEMENT FOR THE SWAPS NOR SOLD THEM THROUGH A NATIONAL SECURITIES EXCHANGE (AS REQUIRED). EQUIDATE, INC. AND EQUIDATE HOLDINGS LLC CONSENTED TO THE SEC'S ORDER WITHOUT ADMITTING OR DENYING THE FINDINGS AND AGREED TO PAY AN $80,000 PENALTY. EQUIDATE, INC. STOPPED OFFERING AND SELLING SECURITY-BASED SWAPS IN DECEMBER 2015 AS A RESULT OF THE SEC INVESTIGATION. EQUIDATE, INC. CHANGED THE STRUCTURE OF ITS TRANSACTIONS IN THE FOURTH QUARTER OF 2015 TO THE FUND STRUCTURE DESCRIBED IN THE ADVISER'S FORM ADV PART 2A. Summary: ON DECEMBER 6, 2016, THE SEC AND EQUIDATE, INC. (AS WELL AS ITS THEN WHOLLY OWNED SUBSIDIARY, EQUIDATE HOLDINGS LLC), AGREED TO SETTLE CHARGES THAT EQUIDATE, INC. AND EQUIDATE HOLDINGS LLC VIOLATED FEDERAL SECURITIES LAWS BY FAILING TO REGISTER SECURITY-BASED SWAPS THAT WERE OFFERED AND SOLD ONLINE TO SHAREHOLDERS IN PRE-IPO COMPANIES. THE SEC INSTITUTED AN ORDER FINDING THAT EQUIDATE, INC. AND EQUIDATE HOLDINGS LLC SOUGHT TO PROVIDE LIQUIDITY FOR EMPLOYEES OF PRIVATE, GROWTH-STAGE COMPANIES IN THE SILICON VALLEY AND OTHERS HOLDING RESTRICTED SHARES OF THEIR STOCK, AND ITS PLATFORM ESSENTIALLY MATCHED THESE SHAREHOLDERS WITH INVESTORS SEEKING TO INVEST IN THE POTENTIAL ECONOMIC RETURN ON THOSE SHARES. EQUIDATE, INC. CONDUCTED TRANSACTIONS THROUGH CONTRACTS THAT ITS SUBSIDIARY ENTERED INTO WITH THE SHAREHOLDERS AND INVESTORS, AND PAYMENT PROVISIONS WERE TRIGGERED BY SUCH EVENTS AS A MERGER, ACQUISITION, OR IPO AT THE UNDERLYING COMPANY. EQUIDATE, INC. AND EQUIDATE HOLDINGS, LLC, HOWEVER, NEVER FILED A REGISTRATION STATEMENT FOR THE SWAPS NOR SOLD THEM THROUGH A NATIONAL SECURITIES EXCHANGE (AS REQUIRED). EQUIDATE, INC. AND EQUIDATE HOLDINGS LLC CONSENTED TO THE SEC'S ORDER WITHOUT ADMITTING OR DENYING THE FINDINGS AND AGREED TO PAY AN $80,000 PENALTY. EQUIDATE, INC. STOPPED OFFERING AND SELLING SECURITY-BASED SWAPS IN DECEMBER 2015 AS A RESULT OF THE SEC INVESTIGATION. EQUIDATE, INC. CHANGED THE STRUCTURE OF ITS TRANSACTIONS IN THE FOURTH QUARTER OF 2015 TO THE FUND STRUCTURE DESCRIBED IN THE ADVISER'S FORM ADV PART 2A.