Lasater Capital Fund 14: Texas Set Aside Its June 9, 2026 Emergency Order on Aug 11; $5.6M Raised

What happened, in order

The signature page of the agreed order PDF is an image we could not read, so the August 11 date is the Board's own listing date, not a date we read on the order.

What the June 9 order alleged

The order is a regulator's statement of what its Enforcement Division presented, not a court finding. It says Lasater Capital “purports to be a private equity and real estate investment firm”, that Fund 14 offered limited partnership interests with minimums of about $100,000 and a $10 million target, “targeted returns of up to twenty percent (20%)”, quarterly cash flow distributions and “a projected two-times equity multiple over approximately five (5) years”. Investors could reach the offering through “websites, webinars, and social media”.

Source: Texas State Securities Board, Order No. ENF-26-CDO-1898, June 9, 2026. All items are allegations in the order.

The order says the firm's website “still touts the success of KeyCity, claiming they have grown their business, protected the entirety of the principal, and never missed a distribution”, and alleges these statements were misleading because the adverse events were not disclosed. It orders the respondents to stop offering securities in Texas unless registered or exempt, to stop acting as dealers or agents, and to stop fraud and misleading offers, and it warns that a knowing violation is a criminal offense with a fine of up to $10,000, two to ten years in prison, or both.

What the August 11 agreed order changed

Sources: Texas State Securities Board, Orders ENF-26-CDO-1898 and ENF-26-CDO-1899.

The undertaking has four steps. First, the respondents must give eligible investors an updated, complete and accurate written disclosure, made “prior to the rescission offer and return of principal”. Second, they must send a letter by overnight courier and email within 30 calendar days of the order, showing the investment date, the amount invested, distributions paid and the potential refund, calculated as the investment less verifiable distributions. Third, the investor has 30 calendar days after receipt to elect a refund. Fourth, the sponsor must pay “within 120 calendar days after the date Respondent Lasater Capital receives their election”. The Board and the sponsor may talk to investors but “shall not insist” that one accept or reject the offer.

Two points of reading. The conclusions of law in the agreed order are limited to registration; the fraud conclusions of the June order do not appear in it, and the sponsor did not admit anything. That is a different outcome from a finding of fraud, and also from a clean result: the order keeps the Texas cease-and-desist and adds the refund program. And paragraph 37 says nothing in it “shall be construed as approval of any current or future securities offering”.

Fund 14 in its own Form D filings

Source: Form D and Form D/A for Lasater Real Estate Fund 14 LP, CIK 2067468. The $750,000 is marked an estimate and “includes amounts that may be payable in the next 12 months”. The ratio to amount sold is 13.4% (our arithmetic).

Rule 506(c) is the exemption that permits general solicitation, which matches the order's description of websites, webinars and social media; every purchaser must then be an accredited investor. For how to read these fields, see our guide to reading a Form D and the 506(b) versus 506(c) census. The selling agent on the 2026 form is shown as soliciting in all 50 states and the District of Columbia, which is why the refund program's Texas-only definition of eligible investor matters to a holder who lives elsewhere. Fund 14 is a Form D filer, not a registered offering: it files no 10-K or 10-Q, so no audited statements are on EDGAR for it.

The KCAP family in Form D: 13 entities, 31 filings

The order names six KeyCity-era funds and properties. We searched EDGAR's Form D index for “Lasater” and “KCAP” and kept entities whose Forms D carry the same Southlake street address (1209 or 1211 South White Chapel Boulevard) or the Fund 14 address. We excluded five filers that match on name only and sit at addresses elsewhere (a biotechnology fund, an access fund, a liquid fund, an oil and gas issuer and a venture studio). The result is 31 filings by 13 entities. Within each entity we treat a new first-sale date as a new offering and take the latest filing of each; we counted “yet to occur” filings as zero.

Source: 31 Forms D and D/A, accessions in the CSV. Total of the 16 amounts: $102,906,552 (our arithmetic). Filings reporting nothing sold (“yet to occur”): KCAP RE Fund III (2021 and October 2025), KCAP Hive Funding (July 2025) and KCAP Villa Gardens Funding (June 2025).

Five cautions before using this table. It is a sum of reported amounts, and some vehicles, such as a “Pref” or “Funding” entity, may invest in another, so the same dollar could appear twice. A Form D reports what the issuer says was sold on the filing date, not what was repaid, lost or is worth now. Two funds, KX Wealth Fund I and KCAP RE Fund II, report first-sale dates in 2020 on filings made in June 2022, about two years later (our arithmetic); the form cannot tell us why. KCAP Lending Fund XIII's original Form D gave a first sale of June 13, 2022 and its amendment gave May 12, 2022, and we used the amendment. Finally, the order names KCAP Meadows at Ferguson, KCAP Dominik and KCAP Holleman Oaks, and we found no Form D filed under those names, so their investors are not visible in this data. Nothing in a Form D says anything about performance or wrongdoing; the point is to show the size of the family a name stands for.

For the wider market this sits in, our census of real estate syndicators in Form D shows how common a one-filing sponsor is, and the real estate syndication Form D dataset shows the amounts raised by the larger ones.

What the documents do not say

• Whether any investor has been refunded. Nothing public records elections or payments. The Board asked for records of payments; it did not publish them.
• What the updated disclosure says. It goes to Fund 14 investors, not to the public.
• How the other KCAP funds are doing. Fund 14 is the only fund the orders cover. The June order's bankruptcies, foreclosures and receivership concern affiliated entities.
• What happens outside Texas. The agreed order defines eligible investors as Texas residents; other states' regulators are not parties to it.
• How the October federal suit ends. It is reported by InvestmentNews as untested allegations by one investor.

What a reader can do with this

If you hold a Lasater, KeyCity or KCAP interest, the records you would need are the ones the documents describe:

• Find which entity you hold. Subscription documents name the legal entity (for example Lasater Real Estate Fund 14 LP or a KCAP RE Fund LP or LLC). Compare it with the entity names in the CSV and look it up on EDGAR; the Form D shows what that entity reported to the SEC.
• Check where you live. The refund offer in the agreed order is for Texas residents who bought, reinvested in or rolled into Fund 14. If you are elsewhere, or hold a different KCAP fund, the order does not set out a program for you.
• Read the letter, if one arrives. The agreed order says it must state the investment date, the amount, distributions paid and the refund figure, and give a 30-day window to elect. Compare those numbers with your own statements and tax forms before the window closes.
• Ask the Board. The Board's June 9, 2026 release says Texans who have been solicited by Lasater Capital, Lasater RE Fund 14 or related entities are encouraged to contact its Enforcement Division through the Board's website; the order's letterhead lists (512) 305-8300.
• Count what is at stake. Money in one private sponsor with a disputed record, no audited statements on EDGAR and no secondary market is a position worth sizing against your whole portfolio, and a loss may have tax consequences that depend on your facts.

FAQ

Sources: Texas State Securities Board, Emergency Cease and Desist Order No. ENF-26-CDO-1898 (June 9, 2026), Agreed Order and Undertaking No. ENF-26-CDO-1899 (listed August 11, 2026), news release of June 9, 2026 and news-publications listing; SEC Forms D and D/A of Lasater Real Estate Fund 14 LP and 12 other Lasater/KCAP entities on EDGAR, read November 2, 2026; InvestmentNews, October 23, 2026 (secondary, for the federal suit). Dates counted between events, ratios and totals are our arithmetic. This is analysis of public documents, not investment, legal or tax advice.