SEC says Florida private lender booked fake fees to inflate fund returns
TCA Fund Management Group / TCA Global Credit Fund · Private direct lender to small businesses (registered adviser)
The case in brief
Visible before detection
Checks that could have surfaced it, on hindsight
Bank credits vs books
Would have compared booked fee income with cash actually received.
Can mislead when: AA only sees the accounts the company links, so an undisclosed account stays invisible. Cash-heavy businesses and timing differences create false flags.
Document authenticity / direct pull
Would have pulled the underlying agreements behind each fee entry.
Can mislead when: The company can refuse consent, and a refusal is itself a flag. Some banks and co-op banks are not on AA yet.
Governance signals
Would have flagged one executive controlling both fee waivers and valuations.
Can mislead when: Private companies file late, so these signals are lagging. Kubr uses them to support other flags, not to prove anything alone.
Where Kubr services would have helped
Valuation context
Offered in India- C11 Would have flagged one executive controlling both fee waivers and valuations.
Financial diligence
Offered in India- C1 Would have compared booked fee income with cash actually received.
- C5 Would have pulled the underlying agreements behind each fee entry.
IC note
Offered in India- C5 Would have pulled the underlying agreements behind each fee entry.
- C11 Would have flagged one executive controlling both fee waivers and valuations.
Portfolio monitor
Offered in India- C1 Would have compared booked fee income with cash actually received.
- C11 Would have flagged one executive controlling both fee waivers and valuations.
Mapped from the checks each service runs. A hindsight reading of public records, not a promise that the failure would have been found.
Same pattern
A summary of public documents. It reports what the sources say. It is not Kubr's finding and not a statement of guilt.