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Choose a citation in the report to read the passage behind it.
Claim being checked
Adviser to the Tollmere Senior Lending Fund; a subsidiary of Tollmere Capital Group, Inc.
Captured passage
“Tollmere Credit Advisers LLC, a wholly owned subsidiary, serves as investment adviser to the Tollmere Senior Lending Fund.”
Retained source · Tollmere Capital Group, Inc. · Annual report (Form 10-K) · Filed 2026-02-27
Claim being checked
Fees an affiliate collected from fund borrowers in 2021–2023 were not credited against management fees, as the governing agreements required.
Captured passage
“Contrary to the funds’ offering memoranda and governing agreements, Respondent did not offset these fees against its management fees.”
Retained source · Administrative proceeding · File No. 3-22418 · page 4 · 2025-02-11
Claim being checked
The order required an independent consultant and a certification within twelve months.
Captured passage
“…shall retain an Independent Compliance Consultant… and shall certify compliance in writing within twelve months.”
Retained source · Administrative proceeding · File No. 3-22418 · page 7 · 2025-02-11
Claim being checked
The manager said the review was complete and fees are offset in full.
Captured passage
“An independent consultant has completed its review of our fee practices… fees received by our affiliates are now offset in full.”
Retained source · Tollmere Capital Group · Statement · 2026-03-04
Claim being checked
Investor letters describe the offset for funds launched after January 2025.
Captured passage
“Tollmere’s letters to investors describe the offset for funds launched after January 2025. Investors in older funds said the letters did not say whether borrower fees are now credited…”
Retained source · The Credit Desk · 2026-06-18
Tollmere Credit Advisers LLC
ReportSourcesBrief
Subject background
Adviser to the Tollmere Senior Lending Fund, a privately offered private-credit fund available to wealth-management clients since 2022. A subsidiary of Tollmere Capital Group, Inc., which is publicly listed.
Key findings
In February 2025 the adviser settled proceedings over fees an affiliate collected from fund borrowers in 2021–2023 and did not credit against the management fee, as the governing agreements required.
The order required an independent compliance consultant and a written certification of compliance within twelve months.
In March 2026 the manager said the review was complete and affiliate fees are now offset in full.
Counterevidence and later developments
A June 2026 report says the investor letters describe the offset only for funds launched after January 2025; the manager says each fund’s offset follows its governing agreement.
Open questions
- Are borrower fees now credited against the Senior Lending Fund’s management fee, and since when?
- Has the certification of compliance been filed?
CollectionBothAdministrative proceedingsCourt releases
Connected actions
By actionDocuments
Related documents
Order instituting proceedingsPublished 2025-02-11 · 9 pages Notice of proposed plan of distributionPublished 2025-09-30 Order approving plan of distributionPublished 2026-01-20In the Matter of Tollmere Credit Advisers LLC
Order Instituting Administrative and Cease-and-Desist Proceedings
Published 2025-02-11 · View on SEC
The governing agreements said such fees would reduce the management fee dollar for dollar.
The Consultant’s review must cover every fund Respondent advises. The certification is due to the Commission staff, not published by it.
Company insider activity
All activityPurchases & sales
Reported company transactions · Forms 3 and 4
Officer · Vice Chair · Tollmere Capital Group, Inc.
Filing history
Filed 2026-03-12 · Form 4Officer · Vice Chair
Filed 2024-03-11 · Form 4Officer · President, Credit
Filed 2019-06-03 · Form 3Officer · President, Credit
Reported as Vice Chair since 2025, after leading credit. The filings show titles and holdings, not who oversees the fee controls today.
Tollmere Capital Group
Tollmere completes fee review
“An independent consultant has completed its review of our fee practices. All of its recommendations have been adopted, and fees received by our affiliates are now offset in full against management fees.”
“We have also appointed a new Head of Credit to lead the business.”
What it found · ¶14
“Contrary to the funds’ offering memoranda and governing agreements, Respondent did not offset these fees against its management fees.”
What it required · ¶22
“Respondent shall retain an Independent Compliance Consultant to review its policies and disclosures concerning fees received by affiliates, shall adopt the Consultant’s recommendations, and shall certify compliance in writing within twelve months.”
The review covers every fund the adviser manages, including the Senior Lending Fund.
Investors in older Tollmere funds ask whether fee fix reaches them
AI reading suggestion Asks whether the offset reaches older funds; quotes the manager’s response.
Tollmere’s letters to investors describe the offset for funds launched after January 2025. Two investors in older funds, including the Senior Lending Fund, said the letters did not say whether borrower fees are now credited against their management fees.
A Tollmere spokesperson said each fund’s offset follows its governing agreement and the consultant’s review covered every fund.
AI-generated report on Tollmere Credit Advisers LLC, saved with its sources.
Findings on page 4; undertakings on page 7.
Former President, Credit; reported as Vice Chair of the parent since 2025.
The manager’s statement that the problems are resolved.
Reporting that the investor letters describe the offset only for newer funds.
Activity
Working assessment savedSarah Collins
Assessment review requestedSarah Collins · to James Walker
Assessment review response savedJames Walker
Current assessment
The manager reports its review complete. Public sources do not show whether borrower fees are now credited against this fund’s management fee.
Unresolved questions
- What do the fund’s offering memorandum and governing agreement say about the offset?
- Does a recent fee calculation show the credit for borrower fees?
- When did remediation take effect for this fund? Is anything excluded?
Next step
Request the offering memorandum, governing agreement and a recent fee calculation from Tollmere before the approved-list committee on 2026-11-12.
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Key findings
Open questions
- Are borrower fees now credited against the Senior Lending Fund’s management fee, and since when?
- Has the certification of compliance been filed?
Follow-up research objective · draft
Find any public statement of when the borrower-fee offset took effect for funds launched before 2025, including the Tollmere Senior Lending Fund, and any investor letters describing it.
Claim being checked
Adviser to the Tollmere Senior Lending Fund; a subsidiary of Tollmere Capital Group, Inc.
Captured passage
“Tollmere Credit Advisers LLC, a wholly owned subsidiary, serves as investment adviser to the Tollmere Senior Lending Fund.”
Retained source · Tollmere Capital Group, Inc. · Annual report (Form 10-K) · Filed 2026-02-27
Claim being checked
The 2025 order found borrower fees an affiliate collected were not credited as the governing agreements said, and required a consultant and a certification.
Captured passage
“Contrary to the funds’ offering memoranda and governing agreements, Respondent did not offset these fees against its management fees.”
Additional supporting passages
“In February 2025 our adviser subsidiary agreed to settle administrative proceedings concerning fees an affiliate received from fund borrowers.”Annual report (Form 10-K) · page 41
Retained source · Administrative proceeding · File No. 3-22418 · page 4 · 2025-02-11
Claim being checked
The manager says the review is complete and fees are now offset in full.
Captured passage
“An independent consultant has completed its review of our fee practices… fees received by our affiliates are now offset in full.”
Retained source · Tollmere Capital Group · Statement · 2026-03-04
Adverse Media
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5 sources · AI reading suggestions on 2
The Credit Desk · 2026-06-18 · News
Investors in older Tollmere funds ask whether fee fix reaches them
Tollmere’s letters to investors describe the offset for funds launched after January 2025. Two investors in older funds, including the Senior Lending Fund, said the letters did not say whether borrower fees are now credited against their management fees.
Allocator Weekly · 2026-09-22 · News
Tollmere to apply fee offset to all funds from 2027
Tollmere told investors it will credit borrower fees against management fees in all of its funds, including those launched before 2025, from January 2027. It did not say how fees received before then were credited.
Tollmere Capital Group · 2026-03-04 · Web
Tollmere completes fee review
An independent consultant has completed its review of our fee practices. All of its recommendations have been adopted, and fees received by our affiliates are now offset in full against management fees.
Allocator Weekly · 2025-04-02 · News
Tollmere names Felix Amberley head of credit
Felix Amberley will lead the credit business. Desmond Keary, who led it since 2019, becomes vice chair of the parent company.
Lakeside Gazette · 2026-07-12 · News
Tollmere Rowing Club takes county title
The Tollmere Rowing Club won the county eights on Saturday.
Comparing The Credit Desk, 2026-06-18, with Allocator Weekly, 2026-09-22
Subject scope · sameMatter scope · same
Later development In September the manager said the offset will apply to all funds from January 2027. How borrower fees were credited before then is not addressed.
Corporate Insiders
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Reporting insiders
Reported holdings
Filing history
Filed 2026-03-12 · Form 4Officer · Vice Chair
Filed 2024-03-11 · Form 4Officer · President, Credit
Filed 2019-06-03 · Form 3Officer · President, Credit
Led the credit business from 2019 to 2025; reported as Vice Chair since.
Reported holdings
Filing history
Filed 2026-03-12 · Form 4Officer · Head of Credit
Filed 2025-04-01 · Form 3Officer · Head of Credit
First filing in April 2025, when he took over the credit business.
Reported holdings
Filing history
Filed 2025-11-17 · Form 4Officer · Chief Executive Officer
Filed 2023-08-02 · Form 4Officer · Chief Executive Officer
Chief executive throughout the period the order covers.
Enforcement Actions
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Find securities enforcement actions involving a person or company, then examine the available complaints, orders and judgments.
Connected actions
Related documents
Administrative publication · File No. 3-22418
Order instituting proceedings
Published 2025-02-11 · View on SEC
Respondent shall pay a civil money penalty of $3,500,000 and shall distribute $11,600,000, plus prejudgment interest, to investors in the affected funds.
Administrative publication · File No. 3-22418
Notice of proposed plan of distribution
Published 2025-09-30 · View on SEC
Machine-read match · PDF page 3
The Fair Fund of $12.4 million will be distributed to investors in eleven private credit funds, including the Tollmere Senior Lending Fund.
Administrative publication · File No. 3-22418
Order approving plan of distribution
Published 2026-01-20 · View on SEC
The plan of distribution is approved. Payments to eligible investors are to be completed within 180 days.
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