Ivan Moad, 43, of Newport Beach, California, was the managing member and sole control person of Moma Fund II, LLC, a California investment vehicle he established in December 2013 to pool investor money. Acting as an investment adviser, Moad raised approximately $1.26 million from at least 17 investors between February 2019 and September 2020, recruiting them largely through the Newport Beach social clubs he frequented and from a circle of people who had previously invested with him in pre-IPO shares. The pitch was specific and appealing: their money would buy employee-owned pre-IPO shares of Palantir Technologies, the data analytics company, before it went public, and those shares could rise significantly after the IPO. Moma Fund’s operating agreement stated the fund’s purpose was to invest in Palantir shares, and disclosed that Moad, as manager, would receive 20% of any profits. He bought the Palantir shares in early September 2020 at an average price of $6.94. Palantir went public on September 30, 2020, and the price rose sharply. Then, according to the SEC, Moad began selling the fund’s shares and transferring the proceeds to his own bank account, ultimately misappropriating over $2.1 million net beyond the 20% he was entitled to. On August 13, 2026, the SEC issued a settled order against him. Misuse of investor money raised for pre-IPO shares also underpinned the cases against Eric Munson of Adit Ventures and Giovanni Pennetta of Sestante Capital.
Without admitting or denying the findings, Moad consented to an SEC order finding that he willfully violated the antifraud provisions of the Securities Act, the Exchange Act, and the Investment Advisers Act, including the provisions governing advisers to pooled investment vehicles. The order bars him from association with any investment adviser, broker, dealer, or other regulated entity, and from serving in various capacities for registered investment companies. It requires him to pay disgorgement of $2,060,075, prejudgment interest of $700,120, and a civil penalty of $236,451, for a total of nearly $3 million. The investigation was handled by the SEC’s Los Angeles office.
Selling Palantir One to Three Times a Month and Sweeping the Cash to a Personal Account
The mechanics of the misappropriation were methodical. After Palantir went public, Moad sold some of the fund’s shares at a profit, transferred the proceeds to Moma Fund’s bank account, used part of the money to pay some investor redemptions, and transferred a portion to himself consistent with his 20% entitlement. But by mid-December 2020, his transfers to his personal account had already exceeded the 20% the operating agreement allowed. From that point through April 2022, according to the SEC, Moad repeatedly misappropriated the fund’s holdings using a consistent pattern: he sold Palantir shares one to three times a month at a substantial profit, transferred the sale proceeds to Moma Fund’s bank account within a day, and then immediately transferred identical or near-identical amounts to his personal bank account. In total, he moved at least $2.91 million to his personal account, well above what he was owed. He spent it on personal expenses, including $608,000 to buy his personal residence in March 2021. By April 2022, he had drained the fund’s brokerage and bank accounts to near-zero balances.
The investors had no idea. Moad never told them he had sold all of the fund’s holdings and taken the proceeds. Instead, between 2021 and early 2024, he sent them annual Form K-1 tax documents that failed to reflect the realized gains on the Palantir shares he had sold and misappropriated. The K-1 is the document that reports a partnership’s income and gains to its investors for tax purposes, and by omitting the realized Palantir gains, Moad’s K-1s concealed the fact that the shares had been sold at all. Investors reviewing their tax documents would have seen nothing to indicate that the fund’s entire position had been liquidated and the money moved to Moad’s personal account.
A Sell Order at $40 for Shares He Had Already Sold Years Before
The most brazen element of the scheme came after the money was already gone. In March 2024, an investor sought to cash out of Moma Fund. Almost immediately, Moad sent investors a letter dated March 18, 2024, informing them he had closed Moma Fund as of the beginning of the month and had placed “a sell order for the entirety of the fund at $40/share” for the Palantir stock. He told them that if $40 per share was not reached by the close of market on December 19, 2024, all of the fund’s Palantir shares would be sold at the open on December 20. He told at least one investor he was closing the fund because it was time for him to be paid his 20% interest. Every part of this was a fiction. Moad had sold all of the Palantir shares years earlier, between December 2020 and April 2022, and had already taken the proceeds. There were no shares left to place a sell order for. The letter described a sell order on a position that no longer existed.
When Palantir’s share price actually reached $40 in October 2024, investors requested their payouts. Moad distributed nothing. As investors complained through early 2025, he offered them false explanations. He told at least one investor he could not make payments because the fund’s assets were frozen during an audit, but he produced no records showing any audit had occurred. Separately, he told several investors he could not pay them back because the smaller brokerage firms where he had originally bought the pre-IPO Palantir shares had taken 20% of the fund’s shares soon after Palantir went public. This too was false: Moad had sold the shares and taken the proceeds years earlier. The excuses about frozen assets and audits are a common feature of the endgame in misappropriation cases, deployed to buy time once investors begin demanding the money that is no longer there.
Selective Repayments and a Recruiting Ground of Social Clubs
Before the SEC’s investigation, Moad repaid certain clients based on the $40 share price, but he has so far repaid only a fraction of what he misappropriated. The manner of repayment compounded the harm: rather than repaying investors pro rata, meaning proportionally across all of them, Moad appears to have repaid selectively, giving several investors their principal and appreciation up to the $40 per share level while paying the remaining investors nothing. Selective repayment of some investors over others, particularly when funds are limited, raises the same fairness concerns that animate the equal-treatment principles at the heart of fiduciary duty. The recruiting ground for the fund is also notable: Moad drew his investors from the Newport Beach social clubs he frequented and from people who had invested with him before. This is the texture of affinity-style fraud, where the operator raises money from a community of personal acquaintances whose trust is rooted in social familiarity rather than independent diligence. The 17 investors who put $1.26 million into Moma Fund believed they held a stake in one of the most closely watched pre-IPO stories of the era. What they actually held, by April 2022, was a position in a fund whose accounts had been drained to near zero.
Conclusion
Ivan Moad raised $1.26 million from 17 people he knew through Newport Beach social clubs, promising them a stake in pre-IPO Palantir shares. He bought the shares at $6.94, watched Palantir go public and soar, and then sold the fund’s position one to three times a month while sweeping the proceeds into his personal account, taking $2.1 million net beyond his 20% cut and spending $608,000 of it on his own house. He hid it with K-1 tax forms that omitted the gains. When an investor asked to cash out in 2024, he sent a letter describing a sell order at $40 per share for Palantir stock he had already sold years earlier. When the price hit $40, he paid out nothing, blaming a frozen audit and a brokerage clawback that never happened. He settled with the SEC for nearly $3 million and a full industry bar. The shares were real once. By the time he described selling them, they were long gone.
