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Clem Borkowski Subject of SEC Fraud Allegations

Clem Borkowski (CRD #: 3235468), an investment adviser registered with SkiHawk Capital Partners, is the subject of an SEC civil action, according to his BrokerCheck record, accessed on August 26, 2021. Clem Borkowski is also a partner at an investment firm called The Convergence Group.

On June 29, 2021, Clem Borkowski became the subject of a civil action by the SEC. The SEC alleges that Clem Borkowski, The Convergence Group, and SkiHawk Capital Partners defrauded three private funds.

Clem Borkowski allegedly made misrepresentations and advised the funds to enter into service agreements with companies he owned, thereby securing payments of millions of dollars.

  1. The SEC alleges this was a material conflict of interest that Clem Borkowski failed to disclose. Clem Borkowski and his co-defendants allegedly stated in private placement memoranda that an advisory board would review transactions to flag conflicts of interest, which allegedly never happened.
  2. Clem Borkowski allegedly falsely represented investments as secured.
  3. The SEC alleges that Clem Borkowski over-valued two of the funds’ assets by millions of dollars, making it possible to charge higher fees.

Earlier Regulatory Action

There is another regulatory action of Clem Borkowski’s record. On March 23, 2017, the Colorado Division of Securities fined Clem Borkowski $50,000 following allegations that he sold unregistered securities and directly or indirectly employed unlicensed sales agents to act as sales representatives. The regulator further alleged that Clem Borkowski maintained client funds without complying with safeguards. He also allegedly filed (or caused to be filed) misleading forms.

As part of the sanctions, Colorado offered a recession to ASI Capital noteholders who purchased ASI Capital promissory notes. Recissions allow investors to cancel their investment without paying fees.

Clem Borkowski Background Information

Clem Borkowski has passed the following exams:

  • Series 65 Uniform Investment Adviser Law Examination
  • Series 63 Uniform Securities Agent State Law Examination
  • Series 6 Investment Company Products / Variable Contracts Representative Examination
  • Series 26 Investment Company Products /Variable Contracts Principal Examination

Clem Borkowski has worked with the following firms:

  • World Group Securities (CRD #: 114473)
  • WMA Securities (CRD #: 32625)

Kurta Law Can Help

If you worked with Clem Borkowski and you have concerns about your investments, contact Kurta Law today. Call 877-600-0098 or email