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SEC v. Estate of Brodacki and Castle Hill Financial - Investment Adviser Fraud

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Filed April 2nd, 2026
Detected April 3rd, 2026
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Summary

The SEC charged the estate of Massachusetts investment adviser John R. Brodacki, III and Castle Hill Financial Group, LLC for breaching fiduciary duties and misappropriating approximately $1.68 million from at least 18 advisory clients. The enforcement action, filed in federal court in Massachusetts on April 2, 2026, alleges violations of Sections 206(1) and 206(2) of the Investment Advisers Act of 1940.

What changed

The SEC filed a complaint in the U.S. District Court for the District of Massachusetts (Case No. 3:26-cv-30055) charging the estate of former investment adviser John R. Brodacki, III and Castle Hill Financial Group, LLC with violations of Sections 206(1) and 206(2) of the Investment Advisers Act of 1940. From approximately June 2018 through September 2025, Brodacki and Castle Hill allegedly induced at least 18 clients—including many elderly, retired, or seriously ill individuals—to transfer funds for purported investments, but instead misappropriated approximately $1.68 million to pay personal expenses, other clients, and family members. The defendants also continued soliciting funds after their associated registered investment adviser terminated the relationship in July 2025.

Compliance officers at registered investment advisers should review their fiduciary duty practices and client fund handling procedures, particularly regarding vulnerable client populations. The SEC seeks disgorgement with prejudgment interest from Brodacki's estate and Castle Hill, plus civil money penalties and a permanent injunction against Castle Hill. Investment advisers should ensure robust controls over client fund management and verify that advisory relationships remain in good standing.

What to do next

  1. Review fiduciary duty practices and client fund handling procedures
  2. Strengthen controls over client fund management for elderly and retired clients
  3. Verify advisory relationships with associated registered investment advisers remain in good standing

Penalties

Disgorgement with prejudgment interest, civil money penalties, and permanent injunction against Castle Hill

Source document (simplified)

More in this Section

The Estate of John R. Brodacki, III and Castle Hill Financial Group, LLC

U.S. SECURITIES AND EXCHANGE COMMISSION

Litigation Release No. 26519 / April 2, 2026

Securities and Exchange Commission v. Personal Representative of the Estate of John R. Brodacki, III and Castle Hill Financial Group, LLC, No. 3:26-cv-30055 (D. Mass. filed Apr. 2, 2026)

SEC Charges Estate of Massachusetts Investment Adviser and his Company for Allegedly Breaching Fiduciary Duties and Misappropriating Client Funds

On April 2, 2026, the Securities and Exchange Commission charged the estate of former investment adviser and Massachusetts resident John R. Brodacki, III and his Massachusetts-based company, Castle Hill Financial Group, LLC, for Brodacki and Castle Hill allegedly breaching their fiduciary duties to at least 18 of their advisory clients and misappropriating approximately $1.68 million in client funds.

The SEC’s complaint, filed in federal district court in Massachusetts, alleges that, from at least June 2018 through September 2025, Brodacki and Castle Hill fraudulently induced their clients – many of whom were elderly, retired or seriously ill – to transfer money to Castle Hill. According to the complaint, Brodacki told the clients that their funds would be used to make investments for their benefit and/or the benefit of their relatives. The complaint alleges, however, that instead of making such investments, Brodacki and Castle Hill used clients’ funds largely to pay Brodacki’s own personal and business expenses, including lavish meals, membership fees to exclusive social clubs, tuition, and travel; to make payments to other advisory clients; and to make payments to Brodacki’s family members. The complaint further alleges that Brodacki and Castle Hill continued to solicit and accept client funds for purported investment advisory services even after the registered investment adviser with which they were associated terminated the relationship in July 2025. According to the complaint, Brodacki died on or about March 23, 2026.

The SEC’s complaint charges Brodacki and Castle Hill with violating Sections 206(1) and 206(2) of the Investment Advisers Act of 1940 and seeks disgorgement with prejudgment interest from Brodacki’s estate and Castle Hill, and a civil money penalty and permanent injunction against Castle Hill.

The SEC’s litigation is being handled by Kevin B. Currid, John Mccann, Heidi M. Mitza, Lou Randazzo, and Kathy B. Shields, all of the SEC’s Boston Regional Office.

Resources

CFR references

15 CFR 275.206(1) 15 CFR 275.206(2)

Named provisions

Section 206(1) - Investment Advisers Act Section 206(2) - Investment Advisers Act

Source

Analysis generated by AI. Source diff and links are from the original.

Classification

Agency
SEC
Filed
April 2nd, 2026
Instrument
Enforcement
Legal weight
Binding
Stage
Final
Change scope
Substantive
Document ID
Litigation Release No. 26519
Docket
3:26-cv-30055

Who this affects

Applies to
Investment advisers Financial advisers
Industry sector
5231 Securities & Investments 5239 Asset Management
Activity scope
Investment Adviser Compliance Fiduciary Duty Client Fund Management
Geographic scope
United States US

Taxonomy

Primary area
Securities
Operational domain
Compliance
Compliance frameworks
Dodd-Frank Investment Advisers Act
Topics
Investment Adviser Fiduciary Duty Misappropriation

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