Mike Vernon

Michael Vernon worked at TCA Fund Management Group Corp. from March 2011 until May 2016. Over that period he held the roles of Senior Analyst and Director of Credit and Operations, and he served as the firm's Chief Operating Officer from July 2015 until May 2016. He was reported to be 39 years old and a resident of Spain at the time of the SEC's September 2020 order.

TCA Fund Management Group Corp. was a Florida-based investment adviser (SEC-registered since August 13, 2014), headquartered in Aventura, Florida, with additional offices in New York, Las Vegas, London, and Melbourne, Australia. It served as adviser to the TCA Global Credit Fund complex — including TCA Global Credit Master Fund LP and its feeder funds domiciled in the Cayman Islands. The Master Fund's strategy was to invest in short-term, senior secured debt and equity-related instruments and to provide investment-banking services for a fee to small and medium-sized companies. As of November 2019, TCA and its affiliates reported roughly $516 million in net asset value across approximately 470 investor accounts.

In May 2020 the SEC charged TCA Fund Management Group Corp. and TCA Global Credit Fund GP Ltd. with fraud, alleging the firm inflated the funds' net asset values and performance by booking non-binding transactions and fraudulent investment-banking fees — producing a record of consistently positive monthly returns that, without the improperly recorded items, would have shown at least 34 months of negative returns since inception. The SEC separately charged former CEO Robert D. Press and former chief portfolio manager Donna M. Silverman. The funds were placed into receivership/liquidation.

As part of this enforcement wave, the SEC entered a settled administrative order against Vernon in September 2020. Without admitting or denying the findings, he consented to a cease-and-desist order, paid a $35,000 civil penalty, and accepted a limitation barring him for three years from acting as an officer or director of, or associating with, any broker, dealer, investment adviser, municipal securities dealer, municipal advisor, transfer agent, or NRSRO — with the right to apply to resume such activities after three years. The SEC found that Vernon assisted in recording the false data on the funds' books that inflated NAVs, and knew or should have known that the resulting figures were sent to investors.

• There is no documented personal angel/seed investment thesis for Michael Vernon. Available public records describe him as an operations and credit executive at a private credit fund adviser, not as an active early-stage equity investor.
• The fund he helped run (TCA Global Credit Fund) pursued a private-credit strategy: short-term, senior secured debt plus equity-related instruments, combined with fee-generating investment-banking services to small and medium-sized companies.
• That strategy targeted established (if smaller) operating companies needing debt/working-capital financing — the opposite end of the risk/stage spectrum from seed-stage angel equity.