We don't know whether they misrepresented the situation or not. But what we do know is that they had no Board of Directors and the level of independent oversig

We don't know whether they misrepresented the situation or not. But what we do know is that they had no Board of Directors and the level of independent oversight was completely inadequate given the sums of money involved. If I was the SEC I would do nothing and simply remind investors like Sequoia of their responsibility to do basic due diligence. Because I really don't know how you can class them as professional investors given the level of incompetence.