Business ProfileforCFP Fund I, LLC

Beginning in or about April 2017, Atwood provided investment advisory services to a pooled investment vehicle, CFP Fund I, LLC, and recommended to members of the public, to invest money in The Fund. At all relevant times, Atwood was the investment manager of The Fund and had discretionary authority of how The Fund invested its money. The Fund’s Private Placement Memorandum (PPM) offers membership interests in The Fund. The PPM indicates The Fund’s business model is to provide secured debt and equity financing to Cannabis Operators. In addition, the PPM indicates that the Manager has broad discretion in selecting and structuring the investments and such investment decisions are not subject to prior review or approval by the members.  

Between April 2017 through December 2021, Atwood provided investment advisory services to at least one California client and collected at least $743,665.70 in fees.  At all relevant times, neither the Department nor the United States Securities and Exchange Commission have issued an investment adviser certificate to any of the Respondents.  Based on the foregoing findings, the Commissioner is of the opinion that the Respondents have conducted business as an investment adviser in this state without first securing from the Commissioner a certificate, authorizing them to do so.

Atwood Consortium LLC, Daniel T. Nero, and John Kirkorian are hereby ordered to desist and refrain from acting as an investment adviser in the State of California unless and until he has first applied for and secured from the Commissioner a certificate, authorizing them to act as an investment adviser, or unless exempt.