September 2025 SEC Updates

1. On September 29, 2025, the SEC charged Prophecy Asset Management, its CEO and CIO Jeffrey Spotts, and its largest sub-adviser Brian Kahn with defrauding investors by concealing hundreds of millions of dollars of losses while collecting millions in management and incentive fees. The defendants raised over $500 million from 2014 through 2020, misleading investors to believe their investments were protected and allocating capital among sub-advisers, when in reality most funds went to Kahn, who incurred massive trading losses. Prophecy Asset Management, Spotts, and the firm’s Chief Compliance Officer, John Hughes, allegedly deceived the funds’ auditor and investors through fabricated documents and sham transactions, resulting in indefinite suspension of redemptions after losses exceeded $350 million. The SEC seeks permanent injunctions, disgorgement with prejudgment interest, civil penalties, and officer and director bars for Spotts and Kahn. This matter is being litigated. https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26414

2. On September 29, 2025, the SEC announced their 2025 New York Regional Compliance Outreach Program Seminar which will be held on November 18, 2025. This year’s event will be held virtually and registration is required.  There will not be an option to attend in-person, and the event is not being recorded.  To register, please click here: https://surveys.sec.gov/jfe/form/SV_esd8pTAGANgWmxw. Registration will close on October 21st or when capacity has been reached.  This year’s seminar is sponsored by the SEC’s Division of Examinations (“EXAMS”), New York Regional Office and will also include updates from staff members in the Division of Enforcement and Private Funds Unit on items of interest to the registrant community. This compliance outreach event will give attendees the opportunity to hear from SEC staff on a range of topics including, current exam priorities, common deficiencies that have been found in recent examinations, hot topics involving advisers and mutual funds, and evaluation of compliance programs. In addition, we will be hosting a panel on new registrant exams which will include findings from recent examinations of newly registered advisers.

3. On September 26, 2025, a Manhattan federal jury found Steven Gallagher liable for a fraudulent “scalping” scheme that earned him over $2.5 million. In the scheme, Gallagher bought up penny stocks, promoted them online through his “Alex DeLarge” handle on X (formerly Twitter), and then sold them for a profit. The SEC had alleged that Gallagher sent thousands of social media messages promoting 31 different microcap stocks. He encouraged his followers to buy these stocks without disclosing that he planned to sell his own shares immediately for a profit after his promotions artificially inflated the price. The “scalping” technique: The SEC defines “scalping” as recommending a stock to others while concealing your intent to sell it. This scheme is considered a type of fraud because it involves an undisclosed conflict of interest. “Marking the close”: The jury also found Gallagher liable for “marking the close” for two of the stocks, which is the practice of buying shares at the end of the trading day to mislead the public about the stock’s price trajectory. After two days of deliberation, the jury found Gallagher liable for the fraud claims. The verdict means he will likely face significant financial sanctions. 

4. On September 26, 2025, SEC chairman Paul Akins, issued a public statement announcing the reinstatement of the SEC’s prior practice of allowing settlement offers in enforcement actions to be considered at the same time as related waiver requests. This change, reversing the prior administration’s approach, is intended to promote fairness, efficiency, and consistency by enabling the Commission to evaluate the full context of a case and its consequences together. While the Commission is not obligated to accept such combined offers, this process provides clarity for settling entities, streamlines staff resources, and supports the Commission’s mission to protect investors, facilitate capital formation, and maintain fair markets.

5. On September 24, 2025, the SEC announced that Jon Kroeper had been named deputy director of the agency’s Division of Trading and Markets.  Mr. Kroeper twice served at the SEC before joining the Financial Industry Regulatory Authority (FINRA), where he worked from 2007 to 2024 as executive vice president in the market regulation department. He led a team of more than 280 analysts, investigators, and managers that conducted automated surveillance and investigations into potential wrongdoing across U.S. equity, exchange-traded products, and fixed income markets. Most recently, Mr. Kroeper was a senior consultant at Patomak Global Partners where he provided consulting and advisory services for the financial services industry. During his first SEC tenure from 1994 to 2000, he was an attorney-advisor, senior counsel, and counselor to a commissioner. At the SEC from 2005 to 2007, Mr. Kroeper served as both counselor to a commissioner and counselor to the chairman, advising on rulemaking, enforcement, and policy matters before the Commission with an emphasis on market structure, exchanges, and broker-dealers.

6. On September 23, 2025, the SEC issued a Notice of Proposed Plan of Distribution and Opportunity for Comment against Summit Planning Group, Inc., a registered investment adviser, and Richard Urciuoli, its sole owner. The SEC found that Summit violated the Advisers Act by improperly holding the iPath Series B S&P 500 VIX Short-Term Futures ETN (VXX) in client accounts for extended periods. This conduct resulted in a collective loss of $443,809 from the affected client accounts. The Fair Fund for this matter includes $109,401.59 collected from the Respondents. The SEC is inviting public comments on the proposed plan for distribution, which aims to compensate clients who were impacted by the improper investment practices. https://www.sec.gov/files/litigation/admin/2025/34-104022.pdf

7. On September 22, 2025, the SEC charged Aaron Freeman and his purported company, Maxnificent Carriers, LLC, with perpetrating a “free-riding” scheme using multiple brokerage accounts, including accounts in the names of two relatives. Freeman deposited checks from closed or unfunded accounts, falsely represented his income and net worth, and engaged in unauthorized trades, resulting in at least $5,463 in net losses to the affected accounts. Freeman misrepresented trading profits, charged clients fictitious fees, and used funds for personal expenses and Ponzi-like payments. The SEC seeks permanent injunctions, disgorgement with prejudgment interest, civil penalties, and a bar from acting as or being associated with an investment adviser. This matter is being litigated. https://www.sec.gov/files/litigation/complaints/2025/comp26407.pdf

8. On September 22, 2025, the SEC charged Pathyam Patel and his purported company, Infinity Wealth Management, LLC, with perpetrating a fraudulent investment scheme. Patel induced at least 15 investors, including college students, to invest over $430,000 by misrepresenting his qualifications, Infinity’s licensure and endorsement by the SEC, and guaranteeing principal and returns. Instead of investing the funds, Patel misappropriated most of the money for personal expenses and Ponzi-like payments, and also charged clients at least $89,000 in fictitious “fees.” The SEC seeks permanent injunctions, disgorgement with prejudgment interest, civil penalties, and a bar from acting as or being associated with an investment adviser. This matter is being litigated. https://www.sec.gov/files/litigation/complaints/2025/comp26406.pdf

9. On September 19, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking to extend the effective date of the final rule establishing Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers (IA AML Rule) from January 1, 2026, until January 1, 2028.  This notice of proposed rulemaking follows the exemptive relief order that FinCEN issued on August 5, 2025.  FinCEN justifies the delay by arguing it would give the agency more time to review and refine the IA AML Rule’s design, better tailor it to the varied business models and risk profiles within the investment adviser sector, and reduce duplicative or unnecessary burdens, while still maintaining protections of the financial system. https://www.federalregister.gov/documents/2025/09/22/2025-18271/delaying-the-effective-date-of-the-anti-money-launderingcountering-the-financing-of-terrorism

10. On September 19, 2025, the SEC charged Prophecy Asset Management, its CEO and CIO Jeffrey Spotts, and its largest sub-adviser Brian Kahn with defrauding investors by concealing hundreds of millions of dollars of losses while collecting millions in management and incentive fees. The defendants raised over $500 million from 2014 through 2020, misleading investors to believe their investments were protected and allocating capital among sub-advisers, when in reality most funds went to Kahn, who incurred substantial trading losses. Prophecy Asset Management, Spotts, and the firm’s Chief Compliance Officer, John Hughes, allegedly deceived auditors and investors through fabricated documents and sham transactions, leading to indefinite suspension of redemptions after losses exceeded $350 million. The SEC seeks permanent injunctions, disgorgement with prejudgment interest, civil penalties, and officer and director bars for Spotts and Kahn. This matter is being litigated. https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26414

11. On September 19, 2025, after a nine-day trial and fewer than four hours of deliberation, a jury in the United States District Court for the Southern District of New York found defendant Steven Gallagher liable for securities fraud and manipulative trading.  Gallagher used his Twitter account to encourage his numerous followers, including many retail investors, to buy stocks in which Gallagher had already amassed holdings. Gallagher then sold those stocks while he continued to recommend others buy them, never disclosing that he was selling the stocks. Gallagher repeated this pattern with over 30 microcap stocks, making illicit trading profits of over $2.6 million. For two of these stocks, Gallagher was also found to have engaged in manipulative trading by “marking the close” – a strategy involving placing end-of-day orders to buy stock at above-market prices to artificially increase the stock’s price.

12. On September 18, 2025, the SEC settled an administrative proceeding against Bloomberg Tradebook LLC, a registered broker-dealer and wholly owned subsidiary of Bloomberg L.P. The SEC found that from September 2018 through June 2019, Tradebook distributed marketing materials that falsely represented its U.S. Options Market Data as “real-time” and delivered in “fractions of seconds,” when in fact Tradebook knew that delays regularly lasted up to several minutes during high-volume periods. Customers were not fully informed of these delays, which at times caused significant differences between displayed and current prices. Tradebook was ordered to cease and desist from future violations and to pay a civil money penalty in the amount of $5,000,000. https://www.sec.gov/files/litigation/admin/2025/33-11390.pdf

13. On September 18, 2025, the SEC issued remarks by Commissioner Peirce at the Investor Advisory Committee (IAC) meeting. The remarks focused on current and emerging issues in investor protection, regulatory engagement, and market structure. Commissioner Peirce highlighted the importance of incorporating diverse investor perspectives into SEC rulemaking and policy initiatives. Topics addressed included ongoing discussions on investor eligibility criteria, transparency in advisory processes, and mechanisms for ensuring meaningful participation from a wide range of market participants. https://www.sec.gov/newsroom/speeches-statements/peirce-remarks-investor-advisory-committee-meeting-091825

14. On September 17, 2025, the SEC and CFTC voted to further extend the date for investment advisers to comply with amendments to Form PF, the confidential reporting form used by certain private fund advisers. The Commissions extended the compliance date to Oct. 1, 2026. https://www.sec.gov/newsroom/press-releases/2025-119-sec-cftc-extend-form-pf-compliance-date-oct-1-2026

15. On September 16, 2025, the SEC announced that it will host a webinar for large investment firms on Regulation S-P compliance. The webinar is designed to provide guidance and practical insights on safeguarding customer information, implementing privacy protections, and meeting obligations under the SEC’s Regulation S-P rules. The SEC emphasized the importance of firms maintaining robust data privacy programs and effective procedures to mitigate risks related to unauthorized access or disclosure of sensitive client information. Panel discussions during the webinar will cover topics including best practices for information security, policies and procedures for protecting customer records, and responding to potential cybersecurity incidents. The SEC encourages all large investment firms to participate in the webinar and submit questions to improve understanding and compliance with Regulation S-P requirements. https://www.sec.gov/newsroom/press-releases/2025-118-sec-host-webinar-large-firms-regulation-s-p

16. On September 11, 2025, the U.S. District Court for the Southern District of Indiana entered a final judgment against James Harrold and the entities he owned and controlled, ordering them to pay a total of $3,780,392.60. Harrold and the entity defendants raised at least $2 million from investors nationwide in connection with a prime bank scheme. The Court permanently enjoined the defendants from further violating applicable securities laws and appointed a Receiver, and the judgment requires joint-and-several payment of $3,635,126 in disgorgement plus $145,266 in prejudgment interest, offset by prior collections in parallel proceedings. This matter is being litigated. https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26409

17. On September 11, 2025, the SEC charged Jian Wu with defrauding registered investment advisers Two Sigma Investments, LP and Two Sigma Advisers, LP by manipulating computer-based algorithmic investment models used to make client investment decisions. Wu secretly altered at least fourteen investment models he created or helped create, causing Two Sigma to trade in amounts, concentrations, and frequencies differing from intended strategies, which resulted in at least $165 million in harm to clients. Wu obtained millions in ill-gotten incentive compensation. The SEC seeks injunctive relief, disgorgement with prejudgment interest, civil penalties, and a bar from acting as or being associated with an investment adviser. This matter is being litigated. https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26398

18. On September 10, 2025, the SEC charged Parker Austin and his advisory firm, Embarcadero Capital Advisors, Inc., with fraud and improper disclosure of client nonpublic personal information. Austin sent client names, account balances, addresses, phone numbers, email addresses, and fees to his personal email while employed at a prior advisory firm and used the information to recruit clients for Embarcadero. Austin also breached a client’s instructions while at his former firm and misrepresented his disciplinary history and termination on Embarcadero’s website and filings. The SEC seeks permanent injunctions, disgorgement with prejudgment interest, and civil penalties. This matter is being litigated. https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26395

19.  On September 10, 2025, the SEC announced that James Moloney has been named as the new Director of the Division of Corporation Finance. In this role, Moloney will oversee corporate disclosure, reporting, and governance programs, with a focus on ensuring transparency and integrity in public company filings. The SEC highlighted his extensive experience in securities regulation and corporate finance as key qualifications for leading the division. Moloney’s appointment is expected to guide the SEC’s approach to emerging corporate governance issues, review of financial disclosures, and evaluation of compliance with disclosure requirements. Stakeholders are encouraged to engage with the Division on ongoing initiatives and provide feedback on proposed guidance and rulemaking. https://www.sec.gov/newsroom/press-releases/2025-115-james-moloney-named-director-division-corporation-finance

20. On September 9, 2025, the SEC charged Tomislav Vukota and his two advisory firms, Vukota Capital Management, LLC and VCM Global Asset Management Ltd., with breaching fiduciary duties and making material misrepresentations to private funds and investors. Vukota and his firms caused private funds to make below-market loans to cover cash shortfalls, sent misleading buyout letters failing to disclose conflicts of interest, and made material misstatements regarding an auditor, assets under management, investment strategy, and filing status. The Defendants settled the SEC’s charges, consenting to injunctions and total combined monetary relief of $6,943,212 in disgorgement, prejudgment interest of $1,766,582, and civil penalties of $1,000,000. This matter is being litigated. https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26393

21. On September 8, 2025, the SEC settled an administrative proceeding against James Warring, Founder and Chief Executive Officer of EagleStone Wealth Advisors, Inc., a registered investment adviser. Warring, who was also majority owner of the firm’s parent corporation, breached his fiduciary duty by engaging in undisclosed conflicted transactions with a client, including arranging a loan to his family members, charging unauthorized and hidden fees, and advising the client to sign agreements that released claims against him and his entities. The SEC barred Warring from association with any investment adviser, broker, or related entity, and prohibited him from serving in roles connected to registered investment companies. Warring was ordered to pay a civil money penalty in the amount of $450,000. https://www.sec.gov/files/litigation/admin/2025/34-103901.pdf

22. On September 8, 2025, the SEC announced that its Crypto Task Force will host a roundtable focused on financial surveillance and privacy in the cryptocurrency and digital asset markets. The roundtable aims to bring together industry participants, regulators, and other stakeholders to discuss challenges and opportunities related to transaction monitoring, data privacy, and regulatory compliance in the rapidly evolving crypto space. The SEC emphasized the importance of balancing investor protection with innovation in the digital asset markets. Panel discussions will include topics such as privacy-preserving technologies, compliance with anti-money laundering obligations, and best practices for reporting suspicious activity.  https://www.sec.gov/newsroom/press-releases/2025-114-sec-crypto-task-force-host-roundtable-financial-surveillance-privacy

22. On September 4, 2025, the SEC released its 2025 Unified Agenda of Regulatory and Deregulatory Actions.  The Unified Agenda includes several proposed and final rulemakings that will impact investment advisers.  Below are the final and proposed rule stages applicable to investment advisers along with key information and hyperlinks to additional information.

Final Rule:

Customer Identification Programs (CIP)

The SEC plans to finalize a Customer Identification Program (CIP) rule by April 2026 requiring investment advisers to implement reasonable procedures to verify the identities of their customers at the account opening.  The CIP rule applies to both retail advisers and private fund advisers, including exempt reporting advisers. 

Below are key provisions of the CIP Rule:

  • Customer Definition: A “customer” is defined as any person, including natural persons and legal entities, who opens a new account with an investment adviser.
  • Account Definition: An “account” encompasses any contractual or business relationship between a person and an investment adviser under which the adviser provides investment advisory services.
  • Required Information: Advisers must collect the following identifying information:
  • Full name
  • Date of birth (for individuals) or date of formation (for entities)
  • Address
  • Identification number (e.g., Social Security Number or Taxpayer Identification Number)
  • Verification Methods: Advisers may use documentary methods (e.g., government-issued ID) and non-documentary methods (e.g., third-party verification) to verify customer identities.
  • Recordkeeping: Advisers must maintain records of the information used to verify identities and determine whether customers appear on lists of known or suspected terrorists or terrorist organizations.
  • Customer Notice: Advisers are required to inform customers that they are requesting identifying information to comply with the CIP rule.
  • Reliance on Third Parties: Advisers may rely on other financial institutions to perform CIP procedures, provided there is a written agreement and the third party is subject to a regulatory authority

On a related topic,  FinCEN announced in July 2025 a proposed two-year delay of the AML rule’s effective date from January 1, 2026, to January 1, 2028. The delay of the AML rule is intended to allow for further review and coordination with the CIP rule.  The CIP rule and AML rule are different, although they are closely related.  The CIP rule is a smaller subset of the AML rule. Below is a breakdown of the key differences between the CIP rule and AML rule:

  • Purpose
  • CIP Rule: To verify the identity of customers at account opening
  • AML Rule: To detect and prevent money laundering and financial crimes
  • Focus
  • CIP Rule: Customer identification and verification at the account opening
  • AML Rule: Ongoing monitoring of transactions and reporting suspicious activities
  • Key Requirement
  • CIP Rule: Collection and verification of customer information
  • AML Rule: Implementation of an AML program, including reporting of suspicious activity
  • Compliance Timeline
  • CIP Rule: Final rule expected by April 2026
  • AML Rule: Final rule expected by January 2028 (Delayed)

Proposed Rule Stage:

The key distinction between the two following proposed rules:

  • Custody Rule Amendments: broader custody modernization for client and fund assets under the Advisers Act.
  • Crypto Assets: targeted initiative addressing crypto-specific issues under both the Advisers Act and Investment Company Act.

II. Custody of Client Assets Rule Amendments (Investment Advisers Act focus).

The SEC is considering recommending amendments to existing rules, and/or proposing new rules, under the Investment Advisers Act to improve and modernize regulations governing the custody of advisory client and fund assets, including the treatment of crypto assets. A proposed rule is expected by April 2026. https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202504&RIN=3235-AN46

Focus: All client and fund assets under the Investment Advisers Act.

Purpose: Modernize custody protections and oversight.

Likely changes:

  • Expanded definition of “custody.”
  • Stronger surprise exam / audit requirements.
  • New standards for using third-party custodians.
  • Updates to how standing letters of authorization (SLOAs) are treated.
  • More disclosure in Form ADV and client agreements.

Who it affects: All advisers with custody, regardless of asset type.

III. Crypto Assets Rulemaking (covers both the Investment Advisers Act and the Investment Company Act, with broader scope beyond custody).

The SEC is considering recommending amendments to existing rules, and/or proposing new rules, under the Investment Advisers Act and the Investment Company Act to improve and modernize regulations applicable to advisory client and fund assets, including specific provisions addressing crypto assets. A proposed rule is expected by April 2026.  https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202504&RIN=3235-AN38

Focus: Digital assets (crypto, tokenized securities, blockchain-based assets).

Purpose: Create clear rules for advisers and funds holding crypto.

Likely changes:

  • Standards for qualified crypto custodians.
  • Requirements for verifying ownership/control of crypto.
  • Segregation and cybersecurity protections (loss/theft of keys).
  • Enhanced disclosure for crypto risks (valuation, liquidity, counterparty).
  • Rules for funds with crypto holdings.

Who it affects: Advisers and funds with any crypto exposure.

IV. Updates to “Small Entity” Definitions for Purposes of the Regulatory Flexibility Act

The SEC is considering recommending amendments to existing rules and/or proposing new rules under the Investment Advisers Act to improve and modernize the regulations around the custody of advisory client and fund assets, including to address in each case crypto assets. A proposed rule is expected by April 2026.   https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202504&RIN=3235-AN39

Why This Matters:

  • The current thresholds for what counts as a “small entity” have not been meaningfully updated in years.
  • Many smaller advisers are caught in a gap—too large for the current definition, but still resource-constrained compared to larger firms.
  • Updating the definition could expand the number of advisers that qualify as “small entities,” giving them regulatory relief.

The SEC’s 2025 Agenda also reflects a change in priorities by withdrawing several rulemakings introduced under the prior administration, including proposals on cybersecurity risk management, outsourcing, and ESG disclosures. The SEC noted that the Agenda is a “snapshot” of current priorities and that timing and scope may shift.

23. On September 3, 2025, the SEC charged Austin Ellison-Meade and his investment club, Baycap.io, with misappropriating investor funds. Ellison-Meade raised at least $2.8 million from approximately 31 investors, promising to use the funds for algorithmic securities trading, but instead diverted money to luxury items and Ponzi-like payments to other investors. The Court entered a final judgment permanently enjoining Ellison-Meade from participating in the issuance, purchase, offer, or sale of any security in an unregistered offering and from violating applicable SEC rules. Ellison-Meade was ordered to pay disgorgement in the amount of $2,917,751 and prejudgment interest of $820,668. This matter is being litigated. https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26389

24. On September 3, 2025, the SEC filed an order setting an administrator’s bond regarding a settled administrative proceeding against Summit Planning Group, Inc., a registered investment adviser, and its sole owner and investment professional, Richard Urciuoli. Urciuoli invested client assets in a volatility-linked exchange-traded product, the iPath Series B S&P 500 VIX Short-Term Futures ETN, for extended periods without a reasonable basis, resulting in client losses of more than $443,000. The SEC also found that Summit failed to adopt and implement policies and procedures reasonably designed to prevent violations of the Advisers Act. Summit and Urciuoli were ordered to pay disgorgement in the amount of $8,476, prejudgment interest of $925 and a civil money penalty in the amount of $100,000. The SEC appointed Simpluris, Inc. as fund administrator and set the administrator’s bond amount at $109,401. https://www.sec.gov/files/litigation/admin/2025/34-103838.pdf

25. On September 3, 2025, the SEC filed an order setting an administrator’s bond regarding a settled administrative proceeding against Merrill Lynch, Pierce, Fenner & Smith Incorporated, a registered broker-dealer and investment adviser, and Harvest Volatility Management LLC, a registered investment adviser. The case involved Merrill Lynch referring clients to Harvest to manage an option overlay strategy, the Collateral Yield Enhancement Strategy. Harvest exceeded client-authorized investment levels, causing overexposure, higher fees, and losses. The SEC found that Harvest failed to adopt and implement policies and procedures reasonably designed to prevent violations, while Merrill Lynch failed to adequately notify clients of overexposure and breached its fiduciary duties. Merrill Lynch was ordered to pay disgorgement of $2,000,000, prejudgment interest of $800,000 and a civil money penalty of $1,000,000. Harvest Volatility was ordered to pay disgorgement of $2,500,000, prejudgment interest of $1,000,000 and a civil money penalty of $2,000,000. Rust Consulting, Inc. was appointed as fund administrator and the administrator’s bond amount was set at $9,300,000. https://www.sec.gov/files/litigation/admin/2025/34-103849.pdf

26. On September 3, 2025, the SEC filed an order setting an administrator’s bond regarding a settled administrative proceeding against Anthony Coronati and Bidtoask, LLC. Coronati owned and controlled Bidtoask, which offered stock recommendations to subscribers, and also acted as chairman and chief executive officer of Corsac Inc., an investment adviser to a fictitious hedge fund. The SEC found that Coronati invested client funds improperly and engaged in fraudulent practices, which led to significant investor harm. Coronati and Bidtoask were ordered to pay monetary relief, though Coronati satisfied only part of the obligation. Coronati was ordered to pay disgorgement in the amount of $292,646, prejudgment interest of $7,353 and a civil money penalty in the amount of $100,000. https://www.sec.gov/files/litigation/admin/2025/34-103847.pdf

27. On September 3, 2025, the SEC filed an order setting an administrator’s bond regarding a settled administrative proceeding against Jeremy Licht d/b/a JL Capital Management, a California registered investment adviser. Licht was the founder, principal, chief compliance officer, and sole owner of the firm. The SEC found that he engaged in fraudulent conduct that violated the Advisers Act and the Exchange Act, resulting in monetary harm to clients. Licht was ordered to pay $88,504 in disgorgement, $8,714 in prejudgment interest, and a $181,071 civil money penalty, for a total of $278,289. https://www.sec.gov/files/litigation/admin/2025/34-103848.pdf

28. On September 4, 2025, the SEC filed an order setting an administrator’s bond regarding a settled administrative proceeding against Securities America Advisors Inc., a registered investment adviser. The SEC found that the firm failed to comply with requirements under the Advisers Act relating to its compliance program and was ordered to pay a $1,750,000 civil penalty. A Fair Fund was created so the penalty could be distributed to harmed investors, and funds were later disbursed to fully compensate eight investors for their losses with interest. The SEC confirmed that the fund administrator completed the process, with all taxes, fees, and expenses paid. The remaining $1,037,709 was ordered to be transferred to the U.S. Treasury, the fund administrator was discharged, and the Fair Fund was terminated. https://www.sec.gov/files/litigation/admin/2025/34-103854.pdf

29. On September 4, 2025, the SEC filed an order setting an administrator’s bond regarding a settled administrative proceeding against Charles Rizzo, co-founder and director of Results One Financial, LLC, and Gina Hornbogen, the firm’s chief compliance officer and equity partner. The SEC found that Rizzo and Hornbogen failed reasonably to supervise another employee, resulting in investor harm. Both were ordered to pay disgorgement, prejudgment interest, and civil penalties, and a Fair Fund was created to distribute these amounts to harmed investors. Rizzo was ordered to pay disgorgement of $35,079, prejudgment interest of $7,731 and a civil money penalty of $130,000. Hornbogen was ordered to pay disgorgement of $15,592, prejudgment interest of $3,467 and a civil money penalty of $25,000. https://www.sec.gov/files/litigation/admin/2025/34-103862.pdf

30. On September 4, 2025, the SEC filed an order setting an administrator’s bond regarding a settled administrative proceeding against Meridian Financial, LLC, a registered investment adviser. The matter involved failures to comply with the Advisers Act related to marketing, recordkeeping, policies and procedures, and the completion of an annual compliance review. Meridian published an advertisement on its public website claiming it “refuse[d] all conflicts of interest,” despite acknowledging conflicts in its Form ADV. The firm also failed to maintain copies of advertisements, implement recordkeeping arrangements with a third-party vendor, and complete required annual compliance reviews. These lapses reflected deficiencies in its compliance program and oversight of disclosures. Meridian Financial was ordered to pay a civil money penalty in the amount of $75,000. https://www.sec.gov/files/litigation/admin/2025/ia-6916.pdf


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