ADMINISTRATIVE PROCEEDING
File No. 3-20072

September 25, 2020 - The Securities and Exchange Commission today announced settled charges against Funding the Gap, LLC, and its principal, Irene P. Carroll, both of Scottsdale, Arizona, in connection with unregistered municipal advisory activity by FTG.

The SEC’s order finds that from at least July 2014 through September 2019, FTG and Carroll provided municipal advice to twelve charter schools located throughout the country in connection with the issuance of municipal bonds, including advising the schools regarding financing structures, interest rates, and underwriter selection. As set forth in the order, the charter schools advised by FTG and Carroll borrowed, through conduit issuers, $222 million through municipal bond offerings. The order finds that while FTG and Carroll provided and FTG was paid for municipal advisory services, neither was registered as a municipal advisor.

The SEC's order finds that FTG violated the registration provisions of Section 15B(a)(1)(B) of the Securities Exchange Act of 1934 and that Carroll caused the violation. Without admitting or denying the findings in the order, FTG and Carroll agreed to cease-and-desist orders and to pay, jointly and severally, a civil penalty of $30,000.

The SEC's investigation was conducted by Michael J. Adler and supervised by Peter J. Diskin of the Enforcement Division's Public Finance Abuse Unit and Atlanta Regional Office.