The SEC Files Civil Complaint Against Investment Management Partners

The Securities and Exchange Commission has filed a civil complaint against Chicago-based RIA firm P/E Capital Investment Management Partners and its CEO, Eliseo Prisno, alleging the firm charged clients more than $2.4 million in undisclosed and unauthorized advisory fees.

According to the SEC’s filing, the misconduct occurred between February 2019 and July 2023. During that time, P/E Capital allegedly sidestepped its brokerage custodian’s protocols by using clients’ login credentials to access accounts and approve inflated billing—without client awareness or consent. The commission further alleges that the firm manipulated multifactor authentication by routing verification messages to mobile phones under its own control, allowing it to impersonate clients and authorize higher fees.

In total, the scheme is said to have impacted more than 220 advisory clients, many of whom the SEC describes as retail investors with limited investment experience. The complaint notes that a significant portion of these clients were of Filipino descent and resided either in the U.S. or the Philippines.

The SEC is pursuing permanent injunctions against both P/E Capital and Prisno, as well as disgorgement of ill-gotten gains with interest, and civil monetary penalties. It also seeks to bar Prisno from association with any investment adviser or broker-dealer in the future.

Court documents filed in the Northern District of Illinois allege that Prisno personally benefitted from the excess fees and was the primary architect of the misconduct. The SEC describes him as the dominant force at P/E Capital—serving as CEO, CCO, and senior investment advisor—responsible for all client-facing and operational decisions.

Prisno began his financial services career at Merrill Lynch in 2007 and joined P/E Capital two years later. He is listed as the firm’s majority owner.

P/E Capital reported $20.5 million in AUM across 120 client accounts as of its most recent Form ADV filing in January. That figure marks a decline from $40.5 million in AUM and 150 clients in mid-2021. The firm disclosed that it collects fees based on AUM percentages, commissions, and performance-based structures.

The SEC’s complaint highlights discrepancies between the firm’s stated fee schedule and actual client charges. While P/E Capital disclosed advisory fees of 2% to 2.4%, the firm reportedly charged clients an average of more than 7% of AUM. The commission claims that in many cases, total fees ended up being two to three times what clients were led to expect.

The firm allegedly exploited its clients’ trust by helping them set up brokerage accounts—gaining access to usernames, passwords, and security credentials in the process. By maintaining control over that information, the SEC contends, P/E Capital was able to bypass safeguards and increase fee caps unilaterally.

Neither Prisno nor the firm responded to inquiries from regulators or media, and court filings show no legal representation listed for either party as of now.

For RIAs and compliance officers, the case serves as a stark reminder of the regulatory scrutiny around fee transparency and cybersecurity protocols. It also underscores the risks of dual control breakdowns in small firms where one individual maintains unchecked authority across compliance, operations, and client servicing.

Wealth managers should view this enforcement action as a cautionary tale—especially as regulators continue to intensify oversight of billing practices, particularly among advisors serving retail and international investors.

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