SEC v. Donald Anthony Wright; and Retirement Specialty Group, Inc., No. 2:24-cv-00065, Middle District of Tennessee (Sept. 10, 2024) — Complaint

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF TENNESSEE
NORTHEASTERN DIVISION
SECURITIES AND EXCHANGE    :
COMMISSION,      :
       :
   Plaintiff,   :
       :
  V.     : Case No.
       :
DONALD ANTHONY WRIGHT     :
and RETIREMENT SPECIALTY   :
GROUP, INC.,    :
      :
  Defendants.   :

COMPLAINT
Plaintiff, the United States Securities and Exchange Commission
(“Commission” or “SEC”), alleges the following:
OVERVIEW
1. Beginning in or around June 2021 through at least July 2023,
Retirement Specialty Group, Inc. (“RSG”), a Tennessee-based SEC-registered
investment adviser, and its principal, Cookeville, Tennessee resident Donald
Anthony Wright (“Wright”) (collectively, “Defendants”) recommended  , offered,  and
sold over $2.4 million in fraudulent promissory notes to at least five RSG advisory
clients and at least one other person.
2. Wright raised this money, at least in part, to support his efforts to
acquire a   faith-based media marketing company.  Specifically, several entities told

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Wright that they could help him secure financing for this acquisition, but insisted that
he first transfer certain amounts to them as a prerequisite.  Lacking these funds
himself, Wright generated the required capital by having his advisory clients and at
least one other investor purchase promissory notes supposedly issued by these
entities (“the Note Issuers”).
3. In selling these notes, Wright made material misrepresentations and
omissions concerning the nature and safety of the investments and the planned use of
proceeds.  For some investments, he misrepresented that he had invested his own
money.  In another instance, Wright recommended and sold a Note Issuer’s
promissory notes to two clients immediately before Wright obtained a loan from the
Note Issuer.  Upon information and belief, the Note Issuer required the sale of these
notes as a prerequisite to loaning Wright any money.
4. Wright also failed to disclose his conflicts of interest to  his clients;
namely, Wright failed to disclose that he and/or RSG had business relationships with
the Note Issuers to help Wright secure funds, including for the purchase of the faith-
based media marketing company, generally, and that he was recommending these
notes so that he could secure financing from the Note Issuers to purchase the
company and to otherwise obtain money, specifically.
5. Wright also sold forged notes that purportedly were issued by one Note
Issuer but, in reality, were issued by Wright without the Note Issuer’s knowledge or

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authorization.  Wright did not disclose that these notes were unauthorized and forged,
or that that he planned to use the note proceeds solely for his personal benefit in an
attempt to obtain financing to purchase the media company and for other purposes.
6. After defrauding investors with the sale of these notes, Wright
repeatedly misled them about the status of their investments and repayments.  This
included   having the clients enter into further agreements with the Note Issuers and, in
at least one instance, falsifying wire transfer information to    mislead a client that
Wright would imminently have funds available to repay the client.
VIOLATIONS
7. Defendants have engaged in acts or practices resulting in violations of
Section 17(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. § 77q(a)],
Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. §
78j(b)], Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5], and Sections 206(1) and (2)
of the Investment Advisers Act of 1940 (“Advisers Act”) [15 U.S.C. § 80b-6(1) and
(2)].  Unless restrained and enjoined by this Court, Defendants will continue to
engage in acts and practices that violate these provisions.
JURISDICTION AND VENUE
8. The Commission brings this action pursuant to Sections 20 and 22 of
the Securities Act [15 U.S.C. §§ 77t and 77v], Sections 21(d) and 21(e) of the
Exchange Act [15 U.S.C. §§ 78u(d) and 78u(e)], and Sections 209(d) and 209(e) of

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the Advisers Act [15 U.S.C. §§ 80b-9(b) and (d)] to enjoin Defendants from engaging
in the transactions, acts, practices, and courses of business alleged in this complaint,
and transactions, acts, practices, and courses of business of similar purport and
object, for civil penalties, and for other equitable relief.
9. This Court has jurisdiction over this action pursuant to Section 22 of the
Securities Act [15 U.S.C. § 77v], Sections 21(d), 21(e), and 27 of the Exchange Act
[15 U.S.C. §§ 78u(d), 78u(e), and 78aa], and Section 214 of the Advisers Act [15
U.S.C. § 80b-14(a)].
10. Defendants, directly and indirectly, made use of the mails, and the
means and instrumentalities of interstate commerce in connection with the
transactions, acts, practices, and courses of business alleged in this complaint.
11. Venue is proper in this Court because certain of the transactions, acts,
practices, and courses of business constituting violations of the Securities Act, the
Exchange Act, and the Advisers Act occurred in the Middle District of Tennessee,
and Defendants reside in this district.
DEFENDANTS
12. Retirement Specialty Group, Inc. is a Tennessee corporation with its
principal place of business in Cookeville, Tennessee.  At all times relevant to the
claims asserted in this Complaint, RSG has been a registered investment adviser.
RSG has been an SEC-registered investment adviser since May 25, 2022, and

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previously was registered with Tennessee and several other states.  As of January 18,
2024, RSG reported approximately $26.8 million of regulatory assets under
management.  RSG advertises itself as a “faith-based” advisor and most of its
advisory clients are Christian.
13. Donald Anthony Wright, age 54, is a resident of Cookeville, Tennessee.
Wright is the President, Chief Executive Officer, and Chief Compliance Officer of
RSG, which he co-owns with his wife.  Wright holds a Series 65 securities license,
and he previously held Series 6 and 63 licenses.
14. Wright is a former Senior Pastor of Faith in the World Church.  During
the relevant period, Wright regularly promoted himself and RSG’s “faith-based”
investment business, including through a SiriusXM talk show, podcasts, and written
materials.
15. Wright used his religious affiliations to primarily target Christian
clients and purported to offer a variety of financial services, including “faith-based
investing.”
DEFENDANTS’ OFFER AND SALE OF
FRAUDULENT PROMISSORY NOTES
16. Beginning in or around 2021, Wright became interested in acquiring a
Christian-based media marketing company located in Texas that represents several
prominent Christian pastors and evangelists.  The acquisition price exceeded $20
million.

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17. Wright lacked the funds for this acquisition and was either unwilling or
unable to obtain traditional financing.
18. In searching for possible ways to raise the necessary capital, Wright
came into contact with and entered into business relationships with at least three
Note Issuers that purported to assist their customers with securing financing for
specific projects.
19. Each of the Note Issuers indicated that they could help Wright obtain
funds – sometimes hundreds of millions of dollars – which Wright could use to
purchase the media marketing company and for other purposes.
20. One of the Note Issuers agreed to loan Wright approximately
$500,000, but, on information and belief, would do so only if Wright first sold $1
million of the Note Issuer’s promissory notes to investors so that the note proceeds
could serve as collateral for the loan to Wright.
21. The other two Note Issuers told Wright that, to access financing to
purchase the media company, Wright would first need to provide them with a
certain amount of capital.
22. To satisfy the requirements of the Note Issuers, Wright began raising
money from his advisory clients and at least one other investor, recommending that
they invest in promissory notes issued by (or purportedly issued by) the Note Issuers.

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23. The promissory notes that Wright recommended, offered,  and sold had
varying maturities and interest rates.  For example, some notes had a one-year
maturity, with principal and 6% annual interest due at maturity.  Other notes had
maturities as short as one month, with principal, monthly interest of up to 20%, and
additional lump-sum payments due at maturity.
24. In some instances, Wright sold forged promissory notes.  Specifically,
Wright used form promissory notes  of one Note Issuer to make it appear that the
Note Issuer was issuing the promissory notes.  In fact, however, the promissory notes
did not come from and were not authorized by the Note Issuer, and Wright used the
proceeds for his own purposes.
25. Of the $2.42   million in promissory notes sold by Wright, approximately
$950,000 consisted of three forged notes sold to two RSG clients and one other
investor.
Wright’s Misrepresentations and Omissions to Investors
26. Wright told several potential promissory note investors that the Note
Issuers were reputable.
27. Regarding at least one Note Issuer, however, the photos of the
“Management Team” shown on that Note Issuer’s website consisted mainly of stock
internet images, not employees of that issuer.

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28. In another instance, a Note Issuer’s note claimed on its face that the
company was a “Morgan Stanley financial fund.”
29. Wright personally repeated the claim that the Note Issuer had a
relationship with Morgan Stanley in correspondence with at least one investor whose
note Wright claimed was issued by the Note Issuer.
30. In fact, however, the Note Issuer had no affiliation with Morgan Stanley
other than as an ordinary customer.
31. In nearly all known instances, the notes stated on their face that they
were secured, including by, for example, a “Multi-Family Commercial Real Estate
Investment Portfolio,” or a “Bank Issued Cash Backed Stand By Letter of Credit.”
32. However, Wright never received any security agreement executed by
any of the Note Issuers and, upon information and belief, no such security
agreements or collateral existed.
33. Some of the promissory notes that Wright fabricated also represented
that the notes were fully secured.  Given that Wright had fabricated the notes, he
knew that the representations regarding security agreements in those notes were also
false.
34. Wright also told some potential investors that the notes were safer and
more stable than the stock market.

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35. In many instances, Wright knew these statements were false.  For
example, Wright knew that he we would send a substantial amount of investment
proceeds to overseas bank accounts in exchange for promises that Wright would
quickly receive hundreds of millions of dollars in financing to purchase the faith-
based media marketing company.
36. Wright never disclosed the actual risk of the promissory notes.
37. In some instances, Wright told potential investors  that Wright himself
had invested substantial funds.
38. In fact, Wright had invested no personal funds.
39. In selling the promissory notes, Wright did not disclose his conflicts of
interest to his advisory cli   ents, including that he had business and financial
relationships with the Note Issuers and was recommending and selling these notes so
that the Note Issuers could assist him with obtaining financing, including financing to
acquire the media marketing company.
Wright’s Fraudulent Use of Investor Proceeds
40. In at least one instance, Wright obtained a personal loan from a Note
Issuer by first convincing two clients to invest in promissory notes issued by the Note
Issuer.
41. Wright accomplished this by transferring client funds to a Note Issuer as
payment for notes and, the following day, obtaining a loan from the Note Issuer.  A

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substantial amount of the loan was funded with proceeds from the note sales, and the
Note Issuer used the remaining note proceeds for various purposes.
42. Wright never disclosed this conflict of interest to the client, i.e., that
Wright was recommending the note so that he could borrow money from the Note
Issuer.
43. An agent of a Note Issuer eventually returned $220,000 of another
client’s investment funds to RSG.
44. RSG and Wright did not return any of those funds to the investor and,
instead, deposited them into an RSG business account, where they were comingled
with other funds and used to pay general business and personal expenses
.
45. Wright also misappropriated the forged note proceeds, using them for
his personal benefit.
46. Specifically, Wright directed most of the approximately $950,000 in
forged note proceeds to be transferred from the investors’ accounts to accounts
owned and controlled by RSG and/or Wright, and directed the remaining proceeds
to be sent from the investors’ accounts to foreign accounts controlled by
individuals and entities who appear to have offered to assist Wright in obtaining
financing.
47. Of the investor money from the forged note transactions transferred to
accounts controlled by RSG and/or Wright, Wright: (i) sent $250,000 to the media

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marketing company in connection with his planned purchase of the company; (ii)
sent at least $360,000 to foreign accounts in hopes of obtaining financing; and (iii)
comingled the remaining money with other money in RSG’s business account.
WRIGHT’S CONTINUED FRAUD AFTER SELLING THE NOTES
48. Upon information and belief, all of the notes that have become due are
in default.  None of the investors have received any of their principal or interest.
49. Once the notes started to default, Wright sought to placate clients by
providing them with updates about the status of their investments.  This included
repeated representations by Wright that payment was imminent and convoluted
explanations for why clients had not received their promised returns.
50. Wright told some clients that “the money is tied up in England” and
“governments need to make sure that the money is clean and no terrorists are
involved.”
51. Wright also blamed the SEC investigation for non-payment, telling at
least one client that RSG was holding back payment until the conclusion of the
investigation.
52. Wright also convinced each investor, including those whose notes had
not yet come due, to execute a “Release of Liability/Waiver Agreement” with the
Note Issuers.

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53. While some of these releases were to be effective upon final payment,
in others the investors expressly acknowledged receipt of final payment even though
they had not received the repayment of principal or any interest.
54. Wright told investors that these releases were one of the final hurdles to
them receiving payment and created the impression that they needed to sign
immediately in order to get their money back.
55. In September 2023, Wright sent at least one client an email in which
he claimed that RSG was about to receive an $8.1 million wire transfer from which
Wright could repay the client, and he attached a wire transfer confirmation to
support his claim.
56. In reality, the wire transfer confirmation was fake, having been altered
by Wright.  RSG never received the $8.1 million.
COUNT I – FRAUD
Violations of Section 17(a)(1) of the Securities Act
[15 U.S.C. § 77q(a)(1)]
57. Paragraphs 1 through 56 are hereby realleged and incorporated herein
by reference.
58. Between June 2021 and at least July 2023, Defendants, in the offer and
sale of the securities described herein, by the use of means and instruments of
transportation and communication in interstate commerce and by use of the mails,

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directly and indirectly, employed devices, schemes and artifices to defraud
purchasers of such securities; all as more particularly described above.
59. Defendants knowingly, intentionally, and/or recklessly engaged in the
aforementioned devices, schemes and artifices to defraud.
60. By reason of the foregoing, Defendants, directly and indirectly, have
violated and, unless enjoined, will continue to violate Section 17(a)(1) of the
Securities Act [15 U.S.C. § 77q(a)(1)].
COUNT II –    FRAUD
Violations of Sections 17(a)(2) and 17(a)(3) of the Securities Act
[15 U.S.C. §§ 77q(a)(2) and 77q(a)(3)]

61. Paragraphs 1 through 56 are hereby realleged and incorporated herein
by reference.
62. Between June 2021 and at least July 2023, Defendants, in the offer and
sale of the securities described herein, by use of means and instruments of
transportation and communication in interstate commerce and by use of the mails,
directly and indirectly:
a. obtained money and property by means of untrue statements of material
fact and omissions to state material facts necessary in order to make the
statements made, in light of the circumstances under which they were made,
not misleading; and

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b.    engaged in transactions, practices and courses of business which would
and did operate as a fraud and deceit upon the purchasers of such securities; all
as more particularly described above.
63. By reason of the foregoing, Defendants, directly and indirectly, have
violated and, unless enjoined, will continue to violate Sections 17(a)(2) and 17(a)(3)
of the Securities Act [15 U.S.C. §§ 77q(a)(2) and 77q(a)(3)].
COUNT III –    FRAUD
Violations of Section 10(b) of the Exchange Act and Sections (a), (b), and (c) of
Rule 10b-5 Thereunder
[15 U.S.C. § 78j(b) and 17 C.F.R. § 240.10b-5 (a), (b), and (c)]
64. Paragraphs 1 through 56 are hereby realleged and incorporated herein
by reference.
65. Between June 2021 and at least July 2023, Defendants, in connection
with the purchase and sale of securities described herein, by the use of the means and
instrumentalities of interstate commerce and by use of the mails, directly and
indirectly:
a. employed devices, schemes, and artifices to defraud;
b. made untrue statements of material fact and omitted to state material
facts necessary in order to make the statements made, in light of the
circumstances under which they were made, not misleading; and

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c. engaged in acts, practices, and courses of business which would and did
operate as a fraud and deceit upon the purchasers of such securities; all as
more particularly described above.
66. Defendants, intentionally, and/or recklessly engaged in the
aforementioned devices, schemes and artifices to defraud, made untrue statements of
material facts and omitted to state material facts, and engaged in fraudulent acts,
practices and courses of business.
67. By reason of the foregoing, Defendants, directly and indirectly, have
violated and, unless enjoined, will continue to violate Section 10(b) of the Exchange
Act [15 U.S.C. § 78j(b)] and Sections (a), (b), and (c) of Rule 10b-5 thereunder [17
C.F.R. § 240.10b-5(a), (b), and (c)].
COUNT IV –    FRAUD
Violations of Sections 206(1) of the Advisers Act
[15 U.S.C. § 80b-6(1)]
68. Paragraphs 1 through 56 are hereby realleged and incorporated herein
by reference.
69. From June 2021 through at least July 2021, while acting as investment
advisers, Defendants  used the mails and the means and instrumentalities of interstate
commerce, directly and indirectly, employed devices, schemes and artifices to
defraud one or more advisory clients and/or prospective clients.

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70. Defendants knowingly, intentionally, and/or recklessly engaged in the
aforementioned devices, schemes and artifices to defraud.
71. By reason of the foregoing, Defendants, directly and indirectly, have
violated, and, unless enjoined, will continue to violate Section 206(1) of the Advisers
Act [15 U.S.C. § 80b-6(1)].
COUNT V –    FRAUD
Violations of Section 206(2) of the Advisers Act
[15 U.S.C. § 80b-6(2)]

72. Paragraphs 1 through 56 are hereby realleged and incorporated herein
by reference.
73. From June 2021 through at least July 2023, Defendants, while acting as
investment advisers, by the use of the mails and the means and instrumentalities of
interstate commerce, directly and indirectly, engaged in transactions, practices, and
courses of business which would and did operate as a fraud and deceit on one or
more advisory clients and/or prospective clients.
74. By reason of the foregoing, Defendants, directly and indirectly, have
violated and, unless enjoined, will continue to violate Section 206(2) of the Advisers
Act [15 U.S.C. § 80b-6(2)].
PRAYER FOR RELIEF
 WHEREFORE, the Commission respectfully prays for:

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I.
Findings of fact and conclusions of law, pursuant to Rule 52 of the Federal
Rules of Civil Procedure, finding that Defendants committed the violations alleged;
II.
An Order permanently restraining and enjoining each Defendant, their officers,
agents, servants, employees, and attorneys from violating, directly or indirectly,

Section 17(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. § 77q(a)],
Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. §
78j(b)], Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5], and Sections 206(1) and (2)
of the Investment Advisers Act of 1940 (“Advisers Act”) [15 U.S.C. § 80b-6(1) and
(2)];
III.
 An Order pursuant to Section 20(e) of the Securities Act [15 U.S.C. § 77t(e)]
and Section 21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)] and its inherent
equitable powers, enjoining Wright from acting as an officer or director of an issuer
that has a class of securities registered pursuant to Section 12 of the Exchange Act
or that is required to file reports pursuant to Section 15(d) of the Exchange Act.
IV.
An Order permanently restraining and enjoining Defendant Wright from
directly or indirectly, including, but not limited to, through any entity controlled by

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him, participating in the issuance, purchase, offer, or sale of any security, provided,
however: (1) such injunction shall not prevent Wright from purchasing or selling
securities listed on a national securities exchange for his own personal account, nor
prevent Wright from purchasing or holding equity securities issued by privately held
companies for his own personal account; and (2) further provided that he may sell
any such equity securities if, and only if, the sale either constitutes a complete
divestment of Wright’s interest in a privately held company or occurs in direct
conjunction with a change in control in a privately held company in which Wright
holds an equity interest.
V.
An Order requiring Defendants to disgorge all ill-gotten gains or unjust
enrichment derived from the activities set forth in this Complaint, together with
prejudgment interest thereon;
VI.
An Order requiring Defendants to pay a civil penalty pursuant to Section 21(d)
of the Exchange Act [15 U.S.C. §78u(d)], Section 20(d) of the Securities Act [15
U.S.C. § 77t(d)], and Section 209(e) of the Advisers Act [ 15 U.S.C. § 80b-9(e)]; and

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VII.
Granting such other and further relief as this Court may deem just, equitable,
and appropriate in connection with the enforcement of the federal securities laws
and for the protection of investors.
This 9
th
 day of September, 2024.
     Respectfully submitted,

/s/    M. Graham Loomis
M. Graham Loomis
     Regional Trial Counsel
     Georgia Bar No. 457868
     [email protected]

     W. Shawn Murnahan
     Senior Trial Counsel
     Georgia Bar No. 529940
     [email protected]

     Attorneys for Plaintiff
     Securities and Exchange Commission
     950 East Paces Ferry Road, NE, Suite 900
     Atlanta, GA 30326
     Tel: (404) 842-7600
     Facsimile: (404) 842-7679

UNITED STATES DISTRICT COURT 
MIDDLE DISTRICT OF TENNESSEE 

NORTHEASTERN DIVISION 

SECURITIES AND EXCHANGE : 
COMMISSION,    : 
       : 
   Plaintiff,   : 
       : 
  V.     : Case No.  
       : 
DONALD ANTHONY WRIGHT  : 
and RETIREMENT SPECIALTY :  
GROUP, INC.,    : 
      : 
  Defendants.   : 
 

COMPLAINT 

Plaintiff, the United States Securities and Exchange Commission 

(“Commission” or “SEC”), alleges the following: 

OVERVIEW 

1. Beginning in or around June 2021 through at least July 2023, 

Retirement Specialty Group, Inc. (“RSG”), a Tennessee-based SEC-registered 

investment adviser, and its principal, Cookeville, Tennessee resident Donald 

Anthony Wright (“Wright”) (collectively, “Defendants”) recommended, offered, and 

sold over $2.4 million in fraudulent promissory notes to at least five RSG advisory 

clients and at least one other person.  

2. Wright raised this money, at least in part, to support his efforts to 

acquire a faith-based media marketing company.  Specifically, several entities told 

Case 2:24-cv-00065     Document 1     Filed 09/09/24     Page 1 of 19 PageID #: 1



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Wright that they could help him secure financing for this acquisition, but insisted that 

he first transfer certain amounts to them as a prerequisite.  Lacking these funds 

himself, Wright generated the required capital by having his advisory clients and at 

least one other investor purchase promissory notes supposedly issued by these 

entities (“the Note Issuers”).    

3. In selling these notes, Wright made material misrepresentations and 

omissions concerning the nature and safety of the investments and the planned use of 

proceeds.  For some investments, he misrepresented that he had invested his own 

money.  In another instance, Wright recommended and sold a Note Issuer’s 

promissory notes to two clients immediately before Wright obtained a loan from the 

Note Issuer.  Upon information and belief, the Note Issuer required the sale of these 

notes as a prerequisite to loaning Wright any money. 

4. Wright also failed to disclose his conflicts of interest to his clients; 

namely, Wright failed to disclose that he and/or RSG had business relationships with 

the Note Issuers to help Wright secure funds, including for the purchase of the faith-

based media marketing company, generally, and that he was recommending these 

notes so that he could secure financing from the Note Issuers to purchase the 

company and to otherwise obtain money, specifically.   

5. Wright also sold forged notes that purportedly were issued by one Note 

Issuer but, in reality, were issued by Wright without the Note Issuer’s knowledge or 

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authorization.  Wright did not disclose that these notes were unauthorized and forged, 

or that that he planned to use the note proceeds solely for his personal benefit in an 

attempt to obtain financing to purchase the media company and for other purposes.         

6. After defrauding investors with the sale of these notes, Wright 

repeatedly misled them about the status of their investments and repayments.  This 

included having the clients enter into further agreements with the Note Issuers and, in 

at least one instance, falsifying wire transfer information to mislead a client that 

Wright would imminently have funds available to repay the client.    

VIOLATIONS 

7. Defendants have engaged in acts or practices resulting in violations of 

Section 17(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. § 77q(a)], 

Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. § 

78j(b)], Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5], and Sections 206(1) and (2) 

of the Investment Advisers Act of 1940 (“Advisers Act”) [15 U.S.C. § 80b-6(1) and 

(2)].  Unless restrained and enjoined by this Court, Defendants will continue to 

engage in acts and practices that violate these provisions. 

JURISDICTION AND VENUE 

8. The Commission brings this action pursuant to Sections 20 and 22 of 

the Securities Act [15 U.S.C. §§ 77t and 77v], Sections 21(d) and 21(e) of the 

Exchange Act [15 U.S.C. §§ 78u(d) and 78u(e)], and Sections 209(d) and 209(e) of 

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the Advisers Act [15 U.S.C. §§ 80b-9(b) and (d)] to enjoin Defendants from engaging 

in the transactions, acts, practices, and courses of business alleged in this complaint, 

and transactions, acts, practices, and courses of business of similar purport and 

object, for civil penalties, and for other equitable relief. 

9. This Court has jurisdiction over this action pursuant to Section 22 of the 

Securities Act [15 U.S.C. § 77v], Sections 21(d), 21(e), and 27 of the Exchange Act 

[15 U.S.C. §§ 78u(d), 78u(e), and 78aa], and Section 214 of the Advisers Act [15 

U.S.C. § 80b-14(a)]. 

10. Defendants, directly and indirectly, made use of the mails, and the 

means and instrumentalities of interstate commerce in connection with the 

transactions, acts, practices, and courses of business alleged in this complaint. 

11. Venue is proper in this Court because certain of the transactions, acts, 

practices, and courses of business constituting violations of the Securities Act, the 

Exchange Act, and the Advisers Act occurred in the Middle District of Tennessee, 

and Defendants reside in this district.   

DEFENDANTS 

12. Retirement Specialty Group, Inc. is a Tennessee corporation with its 

principal place of business in Cookeville, Tennessee.  At all times relevant to the 

claims asserted in this Complaint, RSG has been a registered investment adviser.  

RSG has been an SEC-registered investment adviser since May 25, 2022, and 

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5 
 

previously was registered with Tennessee and several other states.  As of January 18, 

2024, RSG reported approximately $26.8 million of regulatory assets under 

management.  RSG advertises itself as a “faith-based” advisor and most of its 

advisory clients are Christian. 

13. Donald Anthony Wright, age 54, is a resident of Cookeville, Tennessee.  

Wright is the President, Chief Executive Officer, and Chief Compliance Officer of 

RSG, which he co-owns with his wife.  Wright holds a Series 65 securities license, 

and he previously held Series 6 and 63 licenses. 

14. Wright is a former Senior Pastor of Faith in the World Church.  During 

the relevant period, Wright regularly promoted himself and RSG’s “faith-based” 

investment business, including through a SiriusXM talk show, podcasts, and written 

materials. 

15. Wright used his religious affiliations to primarily target Christian 

clients and purported to offer a variety of financial services, including “faith-based 

investing.”     

DEFENDANTS’ OFFER AND SALE OF  
FRAUDULENT PROMISSORY NOTES 

16. Beginning in or around 2021, Wright became interested in acquiring a 

Christian-based media marketing company located in Texas that represents several 

prominent Christian pastors and evangelists.  The acquisition price exceeded $20 

million.  

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17. Wright lacked the funds for this acquisition and was either unwilling or 

unable to obtain traditional financing.   

18. In searching for possible ways to raise the necessary capital, Wright 

came into contact with and entered into business relationships with at least three 

Note Issuers that purported to assist their customers with securing financing for 

specific projects.       

19. Each of the Note Issuers indicated that they could help Wright obtain 

funds – sometimes hundreds of millions of dollars – which Wright could use to 

purchase the media marketing company and for other purposes.     

20. One of the Note Issuers agreed to loan Wright approximately 

$500,000, but, on information and belief, would do so only if Wright first sold $1 

million of the Note Issuer’s promissory notes to investors so that the note proceeds 

could serve as collateral for the loan to Wright. 

21. The other two Note Issuers told Wright that, to access financing to 

purchase the media company, Wright would first need to provide them with a 

certain amount of capital.    

22. To satisfy the requirements of the Note Issuers, Wright began raising 

money from his advisory clients and at least one other investor, recommending that 

they invest in promissory notes issued by (or purportedly issued by) the Note Issuers.   

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23. The promissory notes that Wright recommended, offered, and sold had 

varying maturities and interest rates.  For example, some notes had a one-year 

maturity, with principal and 6% annual interest due at maturity.  Other notes had 

maturities as short as one month, with principal, monthly interest of up to 20%, and 

additional lump-sum payments due at maturity.   

24. In some instances, Wright sold forged promissory notes.  Specifically, 

Wright used form promissory notes of one Note Issuer to make it appear that the 

Note Issuer was issuing the promissory notes.  In fact, however, the promissory notes 

did not come from and were not authorized by the Note Issuer, and Wright used the 

proceeds for his own purposes.  

25. Of the $2.42 million in promissory notes sold by Wright, approximately 

$950,000 consisted of three forged notes sold to two RSG clients and one other 

investor. 

Wright’s Misrepresentations and Omissions to Investors 

26. Wright told several potential promissory note investors that the Note 

Issuers were reputable. 

27. Regarding at least one Note Issuer, however, the photos of the 

“Management Team” shown on that Note Issuer’s website consisted mainly of stock 

internet images, not employees of that issuer. 

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28. In another instance, a Note Issuer’s note claimed on its face that the 

company was a “Morgan Stanley financial fund.” 

29. Wright personally repeated the claim that the Note Issuer had a 

relationship with Morgan Stanley in correspondence with at least one investor whose 

note Wright claimed was issued by the Note Issuer. 

30. In fact, however, the Note Issuer had no affiliation with Morgan Stanley 

other than as an ordinary customer. 

31. In nearly all known instances, the notes stated on their face that they 

were secured, including by, for example, a “Multi-Family Commercial Real Estate 

Investment Portfolio,” or a “Bank Issued Cash Backed Stand By Letter of Credit.” 

32. However, Wright never received any security agreement executed by 

any of the Note Issuers and, upon information and belief, no such security 

agreements or collateral existed. 

33. Some of the promissory notes that Wright fabricated also represented 

that the notes were fully secured.  Given that Wright had fabricated the notes, he 

knew that the representations regarding security agreements in those notes were also 

false.   

34. Wright also told some potential investors that the notes were safer and 

more stable than the stock market. 

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35. In many instances, Wright knew these statements were false.  For 

example, Wright knew that he we would send a substantial amount of investment 

proceeds to overseas bank accounts in exchange for promises that Wright would 

quickly receive hundreds of millions of dollars in financing to purchase the faith-

based media marketing company.  

36. Wright never disclosed the actual risk of the promissory notes. 

37. In some instances, Wright told potential investors that Wright himself 

had invested substantial funds.  

38. In fact, Wright had invested no personal funds. 

39. In selling the promissory notes, Wright did not disclose his conflicts of 

interest to his advisory clients, including that he had business and financial 

relationships with the Note Issuers and was recommending and selling these notes so 

that the Note Issuers could assist him with obtaining financing, including financing to 

acquire the media marketing company.  

Wright’s Fraudulent Use of Investor Proceeds 

40. In at least one instance, Wright obtained a personal loan from a Note 

Issuer by first convincing two clients to invest in promissory notes issued by the Note 

Issuer. 

41. Wright accomplished this by transferring client funds to a Note Issuer as 

payment for notes and, the following day, obtaining a loan from the Note Issuer.  A 

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substantial amount of the loan was funded with proceeds from the note sales, and the 

Note Issuer used the remaining note proceeds for various purposes.  

42. Wright never disclosed this conflict of interest to the client, i.e., that 

Wright was recommending the note so that he could borrow money from the Note 

Issuer.   

43. An agent of a Note Issuer eventually returned $220,000 of another 

client’s investment funds to RSG.    

44. RSG and Wright did not return any of those funds to the investor and, 

instead, deposited them into an RSG business account, where they were comingled 

with other funds and used to pay general business and personal expenses. 

45. Wright also misappropriated the forged note proceeds, using them for 

his personal benefit. 

46. Specifically, Wright directed most of the approximately $950,000 in 

forged note proceeds to be transferred from the investors’ accounts to accounts 

owned and controlled by RSG and/or Wright, and directed the remaining proceeds 

to be sent from the investors’ accounts to foreign accounts controlled by 

individuals and entities who appear to have offered to assist Wright in obtaining 

financing. 

47. Of the investor money from the forged note transactions transferred to 

accounts controlled by RSG and/or Wright, Wright: (i) sent $250,000 to the media 

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marketing company in connection with his planned purchase of the company; (ii) 

sent at least $360,000 to foreign accounts in hopes of obtaining financing; and (iii) 

comingled the remaining money with other money in RSG’s business account.    

WRIGHT’S CONTINUED FRAUD AFTER SELLING THE NOTES 

48. Upon information and belief, all of the notes that have become due are 

in default.  None of the investors have received any of their principal or interest. 

49. Once the notes started to default, Wright sought to placate clients by 

providing them with updates about the status of their investments.  This included 

repeated representations by Wright that payment was imminent and convoluted 

explanations for why clients had not received their promised returns.   

50. Wright told some clients that “the money is tied up in England” and 

“governments need to make sure that the money is clean and no terrorists are 

involved.” 

51. Wright also blamed the SEC investigation for non-payment, telling at 

least one client that RSG was holding back payment until the conclusion of the 

investigation. 

52. Wright also convinced each investor, including those whose notes had 

not yet come due, to execute a “Release of Liability/Waiver Agreement” with the 

Note Issuers. 

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53. While some of these releases were to be effective upon final payment, 

in others the investors expressly acknowledged receipt of final payment even though 

they had not received the repayment of principal or any interest. 

54. Wright told investors that these releases were one of the final hurdles to 

them receiving payment and created the impression that they needed to sign 

immediately in order to get their money back. 

55. In September 2023, Wright sent at least one client an email in which 

he claimed that RSG was about to receive an $8.1 million wire transfer from which 

Wright could repay the client, and he attached a wire transfer confirmation to 

support his claim. 

56. In reality, the wire transfer confirmation was fake, having been altered 

by Wright.  RSG never received the $8.1 million. 

COUNT I – FRAUD 

Violations of Section 17(a)(1) of the Securities Act 
[15 U.S.C. § 77q(a)(1)] 

57. Paragraphs 1 through 56 are hereby realleged and incorporated herein 

by reference. 

58. Between June 2021 and at least July 2023, Defendants, in the offer and 

sale of the securities described herein, by the use of means and instruments of 

transportation and communication in interstate commerce and by use of the mails, 

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directly and indirectly, employed devices, schemes and artifices to defraud 

purchasers of such securities; all as more particularly described above. 

59. Defendants knowingly, intentionally, and/or recklessly engaged in the 

aforementioned devices, schemes and artifices to defraud. 

60. By reason of the foregoing, Defendants, directly and indirectly, have 

violated and, unless enjoined, will continue to violate Section 17(a)(1) of the 

Securities Act [15 U.S.C. § 77q(a)(1)]. 

COUNT II – FRAUD 

Violations of Sections 17(a)(2) and 17(a)(3) of the Securities Act 
[15 U.S.C. §§ 77q(a)(2) and 77q(a)(3)] 

 
61. Paragraphs 1 through 56 are hereby realleged and incorporated herein 

by reference. 

62. Between June 2021 and at least July 2023, Defendants, in the offer and 

sale of the securities described herein, by use of means and instruments of 

transportation and communication in interstate commerce and by use of the mails, 

directly and indirectly: 

a. obtained money and property by means of untrue statements of material 

fact and omissions to state material facts necessary in order to make the 

statements made, in light of the circumstances under which they were made, 

not misleading; and 

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b.  engaged in transactions, practices and courses of business which would 

and did operate as a fraud and deceit upon the purchasers of such securities; all 

as more particularly described above. 

63. By reason of the foregoing, Defendants, directly and indirectly, have 

violated and, unless enjoined, will continue to violate Sections 17(a)(2) and 17(a)(3) 

of the Securities Act [15 U.S.C. §§ 77q(a)(2) and 77q(a)(3)]. 

COUNT III – FRAUD 

Violations of Section 10(b) of the Exchange Act and Sections (a), (b), and (c) of 
Rule 10b-5 Thereunder 

[15 U.S.C. § 78j(b) and 17 C.F.R. § 240.10b-5 (a), (b), and (c)] 

64. Paragraphs 1 through 56 are hereby realleged and incorporated herein 

by reference. 

65. Between June 2021 and at least July 2023, Defendants, in connection 

with the purchase and sale of securities described herein, by the use of the means and 

instrumentalities of interstate commerce and by use of the mails, directly and 

indirectly: 

a. employed devices, schemes, and artifices to defraud; 

b. made untrue statements of material fact and omitted to state material 

facts necessary in order to make the statements made, in light of the 

circumstances under which they were made, not misleading; and 

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c. engaged in acts, practices, and courses of business which would and did 

operate as a fraud and deceit upon the purchasers of such securities; all as 

more particularly described above. 

66. Defendants, intentionally, and/or recklessly engaged in the 

aforementioned devices, schemes and artifices to defraud, made untrue statements of 

material facts and omitted to state material facts, and engaged in fraudulent acts, 

practices and courses of business. 

67. By reason of the foregoing, Defendants, directly and indirectly, have 

violated and, unless enjoined, will continue to violate Section 10(b) of the Exchange 

Act [15 U.S.C. § 78j(b)] and Sections (a), (b), and (c) of Rule 10b-5 thereunder [17 

C.F.R. § 240.10b-5(a), (b), and (c)]. 

COUNT IV – FRAUD 

Violations of Sections 206(1) of the Advisers Act 
[15 U.S.C. § 80b-6(1)] 

68. Paragraphs 1 through 56 are hereby realleged and incorporated herein 

by reference. 

69. From June 2021 through at least July 2021, while acting as investment 

advisers, Defendants used the mails and the means and instrumentalities of interstate 

commerce, directly and indirectly, employed devices, schemes and artifices to 

defraud one or more advisory clients and/or prospective clients. 

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70. Defendants knowingly, intentionally, and/or recklessly engaged in the 

aforementioned devices, schemes and artifices to defraud. 

71. By reason of the foregoing, Defendants, directly and indirectly, have 

violated, and, unless enjoined, will continue to violate Section 206(1) of the Advisers 

Act [15 U.S.C. § 80b-6(1)]. 

COUNT V – FRAUD 

Violations of Section 206(2) of the Advisers Act 
[15 U.S.C. § 80b-6(2)] 

 
72. Paragraphs 1 through 56 are hereby realleged and incorporated herein 

by reference. 

73. From June 2021 through at least July 2023, Defendants, while acting as 

investment advisers, by the use of the mails and the means and instrumentalities of 

interstate commerce, directly and indirectly, engaged in transactions, practices, and 

courses of business which would and did operate as a fraud and deceit on one or 

more advisory clients and/or prospective clients. 

74. By reason of the foregoing, Defendants, directly and indirectly, have 

violated and, unless enjoined, will continue to violate Section 206(2) of the Advisers 

Act [15 U.S.C. § 80b-6(2)]. 

PRAYER FOR RELIEF 

 WHEREFORE, the Commission respectfully prays for: 

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I. 

Findings of fact and conclusions of law, pursuant to Rule 52 of the Federal 

Rules of Civil Procedure, finding that Defendants committed the violations alleged; 

II. 

An Order permanently restraining and enjoining each Defendant, their officers, 

agents, servants, employees, and attorneys from violating, directly or indirectly, 

Section 17(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. § 77q(a)], 

Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. § 

78j(b)], Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5], and Sections 206(1) and (2) 

of the Investment Advisers Act of 1940 (“Advisers Act”) [15 U.S.C. § 80b-6(1) and 

(2)]; 

III. 

 An Order pursuant to Section 20(e) of the Securities Act [15 U.S.C. § 77t(e)] 

and Section 21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)] and its inherent 

equitable powers, enjoining Wright from acting as an officer or director of an issuer 

that has a class of securities registered pursuant to Section 12 of the Exchange Act 

or that is required to file reports pursuant to Section 15(d) of the Exchange Act. 

IV. 

An Order permanently restraining and enjoining Defendant Wright from 

directly or indirectly, including, but not limited to, through any entity controlled by 

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him, participating in the issuance, purchase, offer, or sale of any security, provided, 

however: (1) such injunction shall not prevent Wright from purchasing or selling 

securities listed on a national securities exchange for his own personal account, nor 

prevent Wright from purchasing or holding equity securities issued by privately held 

companies for his own personal account; and (2) further provided that he may sell 

any such equity securities if, and only if, the sale either constitutes a complete 

divestment of Wright’s interest in a privately held company or occurs in direct 

conjunction with a change in control in a privately held company in which Wright 

holds an equity interest. 

V. 

An Order requiring Defendants to disgorge all ill-gotten gains or unjust 

enrichment derived from the activities set forth in this Complaint, together with 

prejudgment interest thereon; 

VI. 

An Order requiring Defendants to pay a civil penalty pursuant to Section 21(d) 

of the Exchange Act [15 U.S.C. §78u(d)], Section 20(d) of the Securities Act [15 

U.S.C. § 77t(d)], and Section 209(e) of the Advisers Act [ 15 U.S.C. § 80b-9(e)]; and 

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VII. 

Granting such other and further relief as this Court may deem just, equitable, 

and appropriate in connection with the enforcement of the federal securities laws 

and for the protection of investors. 

This 9th day of September, 2024.      
     Respectfully submitted, 
      

/s/ M. Graham Loomis 
M. Graham Loomis 

     Regional Trial Counsel 
     Georgia Bar No. 457868 
     [email protected]  
      
     W. Shawn Murnahan 
     Senior Trial Counsel  
     Georgia Bar No. 529940 
     [email protected]  
      
     Attorneys for Plaintiff 
     Securities and Exchange Commission 
     950 East Paces Ferry Road, NE, Suite 900 
     Atlanta, GA 30326 
     Tel: (404) 842-7600 
     Facsimile: (404) 842-7679 

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mailto:[email protected]
mailto:[email protected]