{
 "body": {
  "html": "<p>The SEC posted litigation release LR-26628 on Sept. 4, 2026.</p>\n<p>From the release: \"Without admitting the allegations in the SEC's complaint, Fenster consented to the entry of a final judgment, subject to court approval, in which he agreed to be permanently enjoined from violating the antifraud provisions of Section 17(a) of the Securities Act of 1933, Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder, and Sections 206(1), 206(2), and 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-8 thereunder; to pay $2,516,120.80 in disgorgement plus $450,012.39 in prejudgment interest and a $236,451.00 civil penalty; and to be prohibited from issuing, purchasing, offering, or selling any security, except for purchases or sales for his own personal account, and from being associated with any broker, dealer, or investment adviser.\"</p>\n<p>The SEC alleges, in the release's words: \"Rather, Fenster allegedly misappropriated more than $2.5 million from the fund's investors' funds for gambling, trips, and personal living expenses, and returned the remainder of investors' funds to certain investors whom he hoped would refer new potential investors to the fund.\"</p>",
  "text": "The SEC posted litigation release LR-26628 on Sept. 4, 2026.\n\nFrom the release: \"Without admitting the allegations in the SEC's complaint, Fenster consented to the entry of a final judgment, subject to court approval, in which he agreed to be permanently enjoined from violating the antifraud provisions of Section 17(a) of the Securities Act of 1933, Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder, and Sections 206(1), 206(2), and 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-8 thereunder; to pay $2,516,120.80 in disgorgement plus $450,012.39 in prejudgment interest and a $236,451.00 civil penalty; and to be prohibited from issuing, purchasing, offering, or selling any security, except for purchases or sales for his own personal account, and from being associated with any broker, dealer, or investment adviser.\"\n\nThe SEC alleges, in the release's words: \"Rather, Fenster allegedly misappropriated more than $2.5 million from the fund's investors' funds for gambling, trips, and personal living expenses, and returned the remainder of investors' funds to certain investors whom he hoped would refer new potential investors to the fund.\""
 },
 "claims": [
  {
   "evidence": "Without admitting the allegations in the SEC's complaint, Fenster consented to the entry of a final judgment, subject to court approval, in which he agreed to be permanently enjoined from violating the antifraud provisions of Section 17(a) of the Securities Act of 1933, Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder, and Sections 206(1), 206(2), and 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-8 thereunder; to pay $2,516,120.80 in disgorgement plus $450,012.39 in prejudgment interest and a $236,451.00 civil penalty; and to be prohibited from issuing, purchasing, offering, or selling any security, except for purchases or sales for his own personal account, and from being associated with any broker, dealer, or investment adviser.",
   "kind": "settles",
   "receipt": "LR-26628"
  }
 ],
 "contact": "research@alphanume.com",
 "corrections": [],
 "dek": "The release describes Waldon Fenster as an unregistered investment adviser and founder of a private fund.",
 "desk": "regulatory",
 "desk_label": "Regulatory Actions",
 "entities": [
  {
   "basis": "identifier or the record itself",
   "in_headline": true,
   "name": "Waldon Fenster",
   "role": "respondent"
  }
 ],
 "facts": [
  {
   "key": "respondent",
   "receipt": "LR-26628",
   "source": {
    "path": "text",
    "value": "Waldon Fenster"
   },
   "text": "Waldon Fenster"
  },
  {
   "key": "release_no",
   "receipt": "LR-26628",
   "source": {
    "path": "index:Release No.",
    "value": "LR-26628"
   },
   "text": "LR-26628"
  },
  {
   "key": "release_date",
   "receipt": "LR-26628",
   "source": {
    "path": "index:date",
    "value": "2026-09-04"
   },
   "text": "Sept. 4, 2026"
  },
  {
   "key": "descriptor",
   "receipt": "LR-26628",
   "source": {
    "model_proposed": true,
    "path": "text",
    "value": "unregistered investment adviser and founder of a private fund"
   },
   "text": "unregistered investment adviser and founder of a private fund"
  },
  {
   "key": "conduct_phrase",
   "receipt": "LR-26628",
   "source": {
    "model_proposed": true,
    "path": "text",
    "value": "Misappropriating Client Funds"
   },
   "text": "misappropriating client funds"
  },
  {
   "key": "allegation_quote",
   "receipt": "LR-26628",
   "source": {
    "model_proposed": true,
    "path": "text",
    "value": "Rather, Fenster allegedly misappropriated more than $2.5 million from the fund's investors' funds for gambling, trips, and personal living expenses, and returned the remainder of investors' funds to certain investors whom he hoped would refer new potential investors to the fund."
   },
   "text": "Rather, Fenster allegedly misappropriated more than $2.5 million from the fund's investors' funds for gambling, trips, and personal living expenses, and returned the remainder of investors' funds to certain investors whom he hoped would refer new potential investors to the fund."
  },
  {
   "key": "settle_sentence",
   "receipt": "LR-26628",
   "source": {
    "path": "text (sentence)",
    "value": "Without admitting the allegations in the SEC's complaint, Fenster consented to the entry of a final judgment, subject to court approval, in which he agreed to be permanently enjoined from violating the antifraud provisions of Section 17(a) of the Securities Act of 1933, Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder, and Sections 206(1), 206(2), and 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-8 thereunder; to pay $2,516,120.80 in disgorgement plus $450,012.39 in prejudgment interest and a $236,451.00 civil penalty; and to be prohibited from issuing, purchasing, offering, or selling any security, except for purchases or sales for his own personal account, and from being associated with any broker, dealer, or investment adviser."
   },
   "text": "Without admitting the allegations in the SEC's complaint, Fenster consented to the entry of a final judgment, subject to court approval, in which he agreed to be permanently enjoined from violating the antifraud provisions of Section 17(a) of the Securities Act of 1933, Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder, and Sections 206(1), 206(2), and 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-8 thereunder; to pay $2,516,120.80 in disgorgement plus $450,012.39 in prejudgment interest and a $236,451.00 civil penalty; and to be prohibited from issuing, purchasing, offering, or selling any security, except for purchases or sales for his own personal account, and from being associated with any broker, dealer, or investment adviser."
  }
 ],
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 "headline": "Waldon Fenster agrees to settle SEC charges over allegedly misappropriating client funds, subject to court approval",
 "id": "s_54xt43lci7yw",
 "kind": "story",
 "legal": {
  "allegation": true,
  "stage": "settled_no_admit"
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  "models": [
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    "model": "claude-opus-5",
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   "prompt": "story_review.v2",
   "reviewed_at": "2026-09-29T21:14:16+00:00",
   "reviewers": 2
  },
  "template": "regulatory_action.v4"
 },
 "published_at": "2026-09-30T17:01:46+00:00",
 "receipts": [
  {
   "filed": "2026-09-04",
   "form": "sec-lr",
   "id": "LR-26628",
   "label": "SEC litigation release LR-26628",
   "source": "sec_release",
   "type": "sec_release_no",
   "type_label": "SEC release",
   "url": "https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26628"
  }
 ],
 "record_date": "2026-09-04",
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 "slug": "waldon-fenster-agrees-to-settle-sec-charges-over-allegedly-misappropriating",
 "status": "published",
 "type": "sec_litigation",
 "updated_at": "2026-09-30T17:01:46+00:00",
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