The complaint alleged that from 2014 to 2017, Criterion Wealth Management Insurance Services of Santa Clarita, Calif., Robert Gravette, 54, also of Santa Clarita, and Mark MacArthur, 52 of Newhall, Calif., recommended that their advisory clients invest more than $16 million in four private real estate investment funds without disclosing that the fund managers had paid them more than $1 million, income on top of the fees that defendants were already charging their clients directly.