«In soliciting investments in the Fake Funds, CASPERSEN made the following
false representations to investors, among others: in recognition for his prior work with Park Hill Group, CASPERSEN had been offered a «friends and family» investment allocation in a security that was
allegedly offered by a private equity firm; CASPERSEN was personally investing in the security, and offering it to his family and a limited number of friends; the investment was a credit facility secured by a portfolio of assets owned by one of the Legitimate Funds; the investor would receive quarterly interest payments, ranging from 15 to 20 percent; the investment was practically risk - free, as the loaned funds would remain in a bank account; the investor could withdraw the principal at any time with 90 days» notice; and investor funds should be wired to one of the Fake Fund Accounts.