SEAN GRUSD formed three funds that he claimed would invest in private financial technology companies.  Beginning in 2021, Grusd provided potential investors with marketing materials containing numerous falsehoods about the funds’ purported investment history and successes.  Among other things, the promotional materials falsely claimed that one of Grusd’s funds had been an early investor in successful startup companies, such as Instacart, Coinbase, and Shippo.  Grusd also falsely claimed that he had graduated from a prestigious law school …