SEC v. CHRISTOPHER AUBIN; ANCHOR STATE CAPITAL LLC; and ANCHOR STATE PROPERTIES LLC, No. 1:25-cv-11379, District of Massachusetts (May 27, 2025) — Complaint

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

SECURITIES AND EXCHANGE
COMMISSION,
   Plaintiff,
 v.

CHRISTOPHER AUBIN, ANCHOR
STATE CAPITAL LLC, f/k/a ANCHOR
STATE INVESTMENTS LLC, and
ANCHOR STATE PROPERTIES LLC,
   Defendants,

and

ASHLEY CORCORAN,
                                  Relief Defendant.

      Civil Action No. 25-CV-

COMPLAINT
 Plaintiff, Securities and Exchange Commission (the “Commission”), alleges the
following against defendants Christopher Aubin (“Aubin”), Anchor State Capital LLC, formerly
known as Anchor State Investments LLC, and Anchor State Properties LLC (collectively with
Aubin, “Defendants”) and Relief Defendant Ashley Corcoran (“Corcoran”):
SUMMARY
1. This case involves the misappropriation and misuse of investor assets by Aubin
and his companies, Anchor State Capital LLC and Anchor State Properties LLC.  Together,
Anchor State Capital LLC, formerly known as Anchor State Investments LLC, and Anchor State
Properties LLC will be referred to as “Anchor State.”  Defendants engaged in a fraudulent
scheme and made and used false and misleading statements in connection with the sale of
Anchor State securities.  In total, the Commission estimates that Defendants raised over $2.5
million from at least 24 investors between at least April 2023 and at least December 2024 (the
“Relevant Period”).

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2. As part of their scheme to defraud, Defendants issued Anchor State securities to
investors in the form of “Investment Contracts,” “Real Estate Partner Contracts,” or “Partner
Contracts.”  These contracts, typically signed by Anchor State and by each investor, promised
investors that: (1) Anchor State would use money invested with Anchor State to make short-
term, high-interest rate loans to borrowers as an alternative to traditional financing; (2) some of
Anchor State’s loans were “hard money” loans, meaning that they were secured by the value of
the underlying property for which the loan was being provided and Anchor State would repay the
loans if the borrower defaulted; (3) the loan proceeds would be used solely to finance specific
loans made to Anchor State borrowers; and (4) investors would be repaid their principal and their
investment profit when the investment contracts matured, from the principal and interest
payments made by the loan borrowers.
3. In truth, Defendants made very few real loans to borrowers and instead used
investors’ funds largely to make payments to earlier investors and to pay for Defendants’ own
business expenses and the personal expenses of Aubin and Relief Defendant Corcoran.  Those
personal expenses included lavish meals, luxury travel and vehicles.  Defendants’ scheme thus
has many hallmarks of a Ponzi scheme.
4. In the course of soliciting investments, and lulling investors who were inquiring
about why they had not been repaid when their investments matured, Defendants made numerous
false and/or misleading statements to investors.  Defendants misrepresented: the uses to which
investors’ money had been put, the existence and status of the loans for which the investments
were purportedly made, the purported reasons why Defendants could not repay the loans when
they were due, and the nature and success of Defendants’ business.
5. Defendants were able to keep the scheme going longer than it may otherwise have

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lasted because they were able to convince some investors to roll over the principal and promised
interest from maturing investment contracts into new investment contracts with a higher balance.
Defendants were thus able to avoid the need to make payments on some investment contracts
when they were originally due.
6. In mid-2024, however, Defendants were sued in state court by two investors
whose investment contracts had matured but had not been repaid in full.  Other investors who
were in a similar position joined in that lawsuit in December 2024.
7. As of the date of this Complaint, Defendants have failed to repay at least $2
million in investment principal to investors with matured investment contracts.   This sum does
not account for the investment returns that Defendants promised to these investors.
8. As a result of the conduct alleged herein, Defendants violated, and unless
restrained and enjoined will continue to violate, Section 10(b) of the Securities Exchange Act of
1934 (“Exchange Act”) and Rule 10b-5 thereunder [15 U.S.C. §78j(b); 17 C.F.R. §240.10b-5]
and Section 17(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §77q(a)].  Further,
Relief Defendant Corcoran received proceeds of Defendants’ fraud, which in equity she is not
entitled to retain.
9. Based on these violations, the Commission seeks from Defendants: (1) permanent
injunctions enjoining them from engaging in the transactions, acts, practices, and courses of
business of the type alleged in this Complaint in violation of the federal securities laws; (2)
disgorgement of ill-gotten gains from the unlawful conduct set forth in this Complaint pursuant
to Sections 21(d)(5) and (7) of the Exchange Act [15 U.S.C. §78u(d)(5), (7)], together with
prejudgment interest; (3)   civil penalties pursuant to Section 20(d) of the Securities Act [15
U.S.C. §77t(d)] and Section 21(d)(3) of the Exchange Act [15 U.S.C. §78u(d)(3)], and such other

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relief as the Court may deem appropriate.
10. The Commission also seeks, against Relief Defendant Corcoran, disgorgement of
her ill-gotten gains together with prejudgment interest thereon, and such other relief as the Court
may deem appropriate.
JURISDICTION AND VENUE
11. This Court has jurisdiction over this action pursuant to Sections 20(d)(1) and
22(a) of the Securities Act [15 U.S.C. §77t(d)(1), 77v(a)] and Sections 21(d), 21(e), and 27 of the
Exchange Act [15 U.S.C §§78u(d), 78u(e) and 78aa].
12. Venue is proper in this Court pursuant to Section 22 of the Securities Act [15
U.S.C. §77v(a)] and Section 27 of the Exchange Act [15 U.S.C §78aa].  Defendant Aubin
resided in the District of Massachusetts during the Relevant Period.  Also, certain of the acts,
practices, transactions and courses of business constituting the violations alleged in this
Complaint occurred within the District of Massachusetts, and were effected, directly, or
indirectly, by making use of the means or instrumentalities of transportations or communication
in interstate commerce, or the mails, including the internet and the telephone.  Some of Anchor
State’s investors reside in the District of Massachusetts.
13. Defendants’ conduct involved fraud, deceit, or deliberate or reckless disregard of
regulatory requirements, and resulted in substantial loss, or significant risk of substantial loss, to
other persons.
DEFENDANTS AND RELIEF DEFENDANT
14. On information and belief, Christopher Aubin, age 30, currently resides in
Walpole, Massachusetts, and he resided in Walpole during a portion of the Relevant Period.
During a portion of the Relevant Period, Aubin may have resided in Lincoln, Rhode Island.

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Aubin is the owner and CEO of both Anchor State entities.  Aubin served in the U.S. Marine
Corps.
15. Anchor State Capital LLC, formerly known as Anchor State Investments LLC, is
a Rhode Island corporation with a principal place of business in Providence, Rhode Island.  It
was incorporated on May 11, 2023, and changed its name to Anchor State Capital LLC on
September 30, 2024.  Of the presently-known investors in this scheme, all but two investors were
issued investment contracts in the name of Anchor State Investments LLC.  At all relevant times,
Aubin has exercised control over Anchor State Capital LLC and has run all aspects of its
business.
16. Anchor State Properties LLC is a Rhode Island corporation with a principal place
of business in Providence, Rhode Island.  It was incorporated on October 7, 2024.  Of the
presently-known investors, two were issued investment contracts in the name of Anchor State
Properties LLC and another made his investment payment to Anchor State Properties LLC.  At
all relevant times, Aubin has exercised control over Anchor State Properties LLC and has run all
aspects of its business.
17. Ashley Corcoran, age 27, resides, on information and belief, in Attleboro,
Massachusetts and may have lived, at times, with Aubin in Walpole, Massachusetts.  During at
least part of the Relevant Period, Corcoran was romantically involved with Aubin.
FACTUAL ALLEGATIONS
Aubin’s and Anchor State’s Purported Business
18. On its website, at least on or about June 22, 2024, Anchor State advertised itself
as providing “Access To Capital When You Need It,” and further said that it both provided
lending services to borrowers and provided “Tailored Financial Planning from Accredited

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Professionals” under a heading of “Planning Futures and Investing.”  One of the “Frequently
Asked Questions” was “How Can I Determine Which Investment Opportunity is Right for Me?”
19. By September 21, 2024, the “About Us” tab of Anchor State’s website
represented that Anchor State is “Your Trusted Partner in Financial Success,” and listed
attributes of “Investing with Anchor State,” including stability, cash flow, amortization, tax
benefits, leverage and appreciation, which were all focused on investments in real estate.  Under
another “Private Lending” tab, the website described its private lending business as involving
“hard money lending” that could be available for borrowers “whether you’re looking to fund a
new investment venture, undertake a home renovation project, cover unexpected expenses, or
consolidate debt.”   Anchor State also stated that another aspect of its business was buying houses
from individuals, “No Matter The Condition.”
20. Aubin described his Anchor State business to numerous investors as a short-term,
“hard money” lending company that made loans to borrowers for property-related financing
projects, real estate investments or other business-related purposes.  A “hard money” loan is a
secured loan based on a property’s value rather than loans based on the borrower’s credit
worthiness.  Aubin also told several investors that Anchor State made money on the points and
other fees that borrowers paid to get a loan from Anchor State, and that investors would make
money by selecting one or more of the loans to finance, and their investment return would be the
interest that the borrower paid to Anchor State.
21. Aubin told investors that they could choose which particular projects or loans they
would like to finance with their investment principal.  The investors’ role was passive; they
expected to profit from Defendants’ efforts.  Aubin, and others working with him, typically gave
investors and potential investors lists of loans that were available for financing.  Those lists

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contained information concerning the particular projects to which Anchor State could lend the
investor’s funds, including terms such as the length of the loan, the interest rate, the points the
loan would carry, and the purpose of the loan.  An excerpt of one of these available loan lists
appears below:

22. To memorialize investors’ investments, Anchor State provided investors with a
contract.  These contracts, which for different investors were titled “Investment Contracts,”
“Partner Contracts,” and/or “Real Estate Partner Contracts,” had generally similar terms and
were typically signed both by Anchor State and by the investor.
23. Anchor State’s investment contracts stated that investors would receive returns of
between 12% and 19% for investments lasting between one month and eight months.
24. The investment contracts typically stated that Anchor State was “engaged in the
business of LENDING (e.g. expansion, construction flips, hard money, real-estate purchases,
etc.),” stated that Anchor State “desires to use the Investor’s funds to fund this event in

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consideration for the items listed in this Agreement,” and provided that “[n]o other expenses may
be paid for with the Funds the Investor provides the Company.”
25. The investment contracts each matured on a specified date (usually between one
and eight months in the future) and typically provided that investors would be repaid their
principal plus their investment return when the investment matured.  Several investment
contracts provided that investors would be paid monthly interest, with the principal to be repaid
when the investment matured.
26. The investment contracts offered by Defendants between July 2023 and early
June 2024 also promised that, if the loan to finance the selected project defaulted, Anchor State
would back the investor with its own equity, assets, and funds.  The investment contracts offered
in June 2024 and July 2024 provided that, in the event of a default, Anchor State would “work in
a timely manner to return principal to investor.”  After July 2024, the provisions about what
would happen in the event of a default were removed (except as to one investor who had made
multiple investments dating back to November 2023).
27. Investors typically transferred their investment funds to Anchor State by check,
wire transfer, or, in a few instances, by giving cash to Aubin.
28. Aubin’s sales pitch to potential investors included his trustworthiness as a Marine
Corp veteran.  At least two of Defendants’ investors were Marine Corps veterans who had served
with Aubin.
29. Relief Defendant Corcoran performed some work for Anchor State.  She
responded to inquiries by some investors when their investment funds were not repaid when
those funds were due.

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30. To date, the Commission has identified at least 24   investors who invested with
Anchor State during the Relevant Period.  Those 24 investors invested over $2.5 million with
Anchor State.
Examples of Specific Investments
31. Investor 1 entered into a “Real Estate Partner Contract” with Anchor State on
August 26, 2024, pursuant to which he invested $50,000.  The contract promised Investor 1 a
return of 12% for an investment that would mature in approximately one month, on September
30, 2024.  Thus, Investor 1 expected to be repaid $56,000.  In verbal discussions, Aubin told
Investor 1 that his money would be used for a hard money loan that would serve as the down
payment for land and that Anchor State was in “first position” with respect to the land.
32. When Investor 1’s investment matured, Aubin told Investor 1 that the land deal
had closed and he had the money to repay Investor 1.  Aubin sent Investor 1 a purported
screenshot from his bank system that showed a wire transfer of $56,000 was processing.  This
screenshot appears to have been fabricated.  The wire transfer did not arrive in Investor 1’s bank
account and Aubin told Investor 1 that he had changed banks and there was a problem because
his account had been flagged.  Aubin then promised to send Investor 1 a check.  The check never
arrived.
33. At the time of Investor 1’s investment, Anchor State maintained bank accounts at
TD Bank, N.A. (“TD Bank”).  Aubin was the sole authorized signatory on Anchor State’s bank
accounts.
34. Anchor State’s bank records show that Investor 1’s funds were not used to make
investments, contrary to the representations in the Real Estate Partner Contract.  Rather, a

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portion of Investor 1’s funds were used to fund payments to another investor and certain
unknown individuals; another portion was transferred to Aubin’s personal account.
35. Investor 2 entered into an “Investment Contract” with Anchor State on January 4,
2024, pursuant to which he wired $145,500 to Anchor State’s bank account.  This investment
was supposed to mature three months later, on April 4, 2024.  Before Investor 2 entered into this
Investment Contract, Anchor State sent Investor 2 a list of “Loans for investment as of January
2
nd
, 2024,” which contained information concerning the particular projects to which Anchor
State could lend Investor 2’s funds, including terms, such as the length of the loan, the interest
rate, the points it would carry, and the purpose of the loan.  Investor 2 chose to invest in projects
that were described as “driveway in Smithfield,” “septic system putnam,” “lot clearing in foster,”
“land clearing cumberland,” and “[a]ddition in warwick RI,” and Anchor State provided him
with an account statement listing the loans he had chosen to finance and stating that Anchor State
owed him a total of $171,553.75 in principal and profit on his investment.  This list of loans
provided by Anchor State indicated that each of these loans carried an interest rate of between
17.5% and 18%.
36. When Investor 2’s Investment Contract matured, he requested payment from
Aubin.  Aubin promised to pay him promptly, but then provided a series of excuses for why he
could not repay Investor 2.
37. At the time of Investor 2’s investment, Anchor State maintained bank accounts at
TD Bank.  Aubin was the sole authorized signatory on Anchor State’s bank accounts.
38. Anchor State’s b ank records show that it made two payments to Investor 2
totaling $29,345: one wire payment of $26,845 on April 23, 2024 and one check for $2,500 dated
May 1, 2024.  In addition, Aubin left a check for Investor 2 and other investors at a business

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owned by another investor.  When Investor 2 attempted to deposit that check in the amount of
$144,708.75 from Anchor State, which was dated May 9, 2024, the check bounced.  At the time
Aubin provided this check to Investor 2, he knew or was reckless in not knowing it would
bounce because Anchor State’s accounts were not even close to containing sufficient funds to
pay it.
39. Since that time, Investor 2 has received no other payments from Aubin or Anchor
State.  Investor 2 continues to contact Aubin to seek payment and Aubin gives him a variety of
excuses about why Aubin and Anchor State cannot pay, including that he had repaid some other
investors, that he had gotten in over his head with a social media influencer circle and could not
handle his business, that he had problems caused by a lawsuit filed by several investors and that
an attorney had taken his money.
40. Anchor State bank records show that Investor 2’s funds were not used to make the
five loans contemplated by his investment contract.  Rather, those bank records show that
Investor 2’s funds were combined with funds from another investor, and were used to fund a
large ($294,629) transfer to a title and closing company, as well as transfers to another investor
and other individuals, two cash withdrawals, and two transfers of funds to Aubin’s personal
account.
41. Investor 3 entered into a “Partner Contract” with Anchor State on June 24, 2024,
pursuant to which she invested $85,000.  The contract promised Investor 3 a return of 19% for an
investment that would mature in approximately three months, on September 20, 2024.  Thus,
Investor 1 expected to be repaid $101,150.  Before her investment, Anchor State sent Investor 3
a list of projects in which she could invest.  Investor 3 understood, based on her discussions with
Aubin and the language in her Partner Contract, that her investment would be used only to

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finance the two projects that she had selected from Anchor State’s list of loans that were
available for investment.
42. To pay for her investment, Investor 3 wrote a check for $85,000 on her
company’s account at BayCoast Bank.  Aubin personally collected the check from Investor 3 on
June 24, 2024.  Investor 3 made the check out to Aubin personally but wrote “Anchor State
AM01-02” in the check’s memo line, which was a reference to the numbers of the two projects
in which she chose to invest.
43. Later in the day on June 24, 2024, Aubin took Investor 3’s check to BayCoast
Bank and cashed the check.  Aubin received a $75,000 bank check and $10,000 in cash.  He then
immediately used $55,000 of the $75,000 check to open a personal account in his own name at
BayCoast Bank and took out another $20,000 in cash.  Later that day, Aubin went to a different
BayCoast Bank branch and withdrew $7,000 in cash and paid his attorney $8,000 from his new
personal account, leaving a $40,000 balance.  The next morning, June 25, 2024, Aubin paid
another investor $24,570 from his BayCoast personal account by check.  Later that day, Aubin
went to a  third BayCoast Bank branch and withdrew the remaining $15,430 in the form of a bank
check for $10,000 (plus a $5 fee) and $5,425 in cash and closed his personal account at
BayCoast Bank.  Thus, Aubin did not use Investor 3’s investment funds to finance two projects
as Defendants had promised.  Rather, Aubin used her funds to repay another investor and for his
own personal and/or business expenses.
44. When Investor 3’s loan was about to mature, Aubin asked Investor 3 if she would
like to roll over her investment into another project.  Investor 3 decided to withdraw her
investment in cash.  Aubin gave Investor 3 various excuses about why she was not being repaid.
Aubin sent Investor 3 a Fund Withdrawal Form so that Anchor State could repay her investment

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by wire transfer.  Investor 3 completed and returned that form to Defendants but was not repaid.
45. Throughout the fall of 2024, Investor 3 spoke to Aubin about weekly.  On
multiple occasions, Aubin told Investor 3 that she would be repaid within a few days but the
repayments were never forthcoming and he would give her excuses as to why the payments were
not made.  Those excuses related to aspects of Aubin’s personal life and his tax obligations.
46. To date, Defendants have not repaid any of Investor 3’s principal or promised
investment income.
Aubin and Anchor State Misrepresented the Uses of Investors’ Funds and their Conduct is
Characteristic of a Ponzi Scheme

47. Defendants’ representations that investors’ funds would be used only to provide
loans to Anchor State borrowers and would not be used for other purposes were, in many
instances, false and misleading.  At the time they made these representations, Aubin and Anchor
State knew, or had reason to know, or were reckless in not knowing, that the money invested by
their investors was not, and would not be, used to fund the loans that were described in the
investors’ investment contracts.  Anchor State’s bank records show few, if any, disbursements of
funds in dates or amounts that match the loans that were described in the investors’ investment
contracts.  Further, Anchor State’s bank records do not show repayments from borrowers to
Anchor State.
48. Instead, Anchor State’s bank records show a pattern of investors’ funds being
disbursed shortly after they were deposited to fund, among other things:  1) payments to other
investors whose investment contracts had matured, 2) payments to personal bank accounts
belonging to Aubin, 3) cash withdrawals, and 4) payments to various entities for Aubin’s and/or
Corcoran’s living expenses and luxury travel.

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49. The use of later investors’ funds to repay earlier investors whose investments had
matured is characteristic of a Ponzi scheme.
50. In addition, Aubin solicited certain investors to “roll over” their principal and
investment return into a subsequent investment, i.e. decline to take the payout and instead
directly reinvest the proceeds in the scheme.  Such an approach is characteristic of a Ponzi
scheme because it allows the operator of the Ponzi scheme to avoid needing to make a payout,
thereby keeping investor funds under his or her control.
51. Many Anchor State investors whose investment contracts have matured have not
been repaid either their principal or promised investment return.  Based on the information
available to the Commission, Aubin and Anchor State took in at least $2 million more in investor
deposits than they have repaid to investors.
Relief Defendant Corcoran Benefitted Financially From Defendants’ Fraud
52. Aubin and Anchor State transferred proceeds from their fraudulent investment
scheme to Relief Defendant Corcoran for no legitimate purpose or consideration.
53. On information and belief, on or about February 7, 2024, Aubin spent about
$66,805 from Anchor State’s bank accounts to purchase a BMW automobile.  Aubin then gave
that automobile to Corcoran for her personal use.  Corcoran thus received a personal benefit to
which she was not entitled.
54. On numerous occasions in 2023 and 2024, funds from Anchor State’s bank
accounts were used to pay for luxury travel, including private jet transport, for Aubin and
Corcoran.  Corcoran thus received a personal benefit from these gifts of travel to which she was
not entitled.
55. On April 23, 2024, Aubin transferred $20,000 from one of Anchor State’s bank

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accounts to his personal bank account and then, the same day, withdrew $15,000 from that
personal account in the form of a bank check made payable to Corcoran’s mother with a notation
on the check that it was “Re: Ashley E. Corcoran.”  On information and belief, Corcoran thus
received a personal benefit from this indirect withdrawal from Anchor State’s bank account to
which she was not entitled.
56. Between about October 28 and December 10, 2024, a total of $22,400 was
transferred from Anchor State Properties’ bank account to a personal account jointly owned by
Aubin and Corcoran at Bank of America.  On information and belief, Corcoran received a
personal benefit from the expenditure of the funds in the bank account she jointly owned with
Aubin.
FIRST CLAIM FOR RELIEF
FRAUD IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES

Defendants’ Violations of Section 10(b) of the Exchange Act and Rule 10b-5 thereunder

57. Paragraphs 1 through 56 above are re-alleged and incorporated by reference as if
fully set forth herein.
58. By reason of the conduct described above, Defendants, directly or indirectly, in
connection with the purchase or sale of securities, by the use of the means or instrumentalities of
interstate commerce or of the mails, or of any facility of any national securities exchange,
intentionally, knowingly, or recklessly, (i) employed devices, schemes, or artifices to defraud;
(ii) made untrue statements of material facts or omitted to state material facts necessary to make
the statements made, in the light of the circumstances under which they were made, not
misleading; and/or (iii) engaged in acts, practices, or courses of business which operated or
would operate as a fraud or deceit upon any persons, including purchasers or sellers of the
securities.

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59. Defendants’ conduct involved fraud, deceit, manipulation or deliberate or reckless
disregard of regulatory requirements and directly or indirectly resulted in substantial losses to
other persons.
60. By reason of the conduct described above, Defendants violated Exchange Act
Section 10(b) [15 U.S.C. §78j(b)] and Rule 10b-5 [17 C.F.R §240.10b-5] thereunder.
SECOND CLAIM FOR RELIEF
FRAUD IN THE OFFER OR SALE OF SECURITIES

Defendants’ Violations of Sections 17(a) of the Securities Act

61. Paragraphs 1 through 56 above are re-alleged and incorporated by reference as if
fully set forth herein.
62. By reason of the conduct described above, Defendants, directly or indirectly, in
connection with the offer or sale of securities, by the use of the means or instrumentalities of
interstate commerce or of the mails, directly or indirectly, acting intentionally, knowingly,
recklessly, or negligently: (i) employed devices, schemes, or artifices to defraud; (ii) obtained
money or property by means of untrue statements of material fact or by omitting to state material
facts necessary in order to make statements made, in the light of the circumstances under which
they were made, not misleading; or (iii) engaged in transactions, practices, or courses of business
which operated or would operate as a fraud or deceit upon any persons, including purchasers or
sellers of the securities.
63. By reason of the conduct described above, Defendants violated Securities Act
Sections 17(a) [15 U.S.C. §77q(a)] and will continue to violate that section unless enjoined.
THIRD CLAIM FOR RELIEF
OTHER EQUITABLE RELIEF, INCLUDING
UNJUST ENRICHMENT AND CONSTRUCTIVE TRUST

As to Relief Defendant Corcoran

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64. Paragraphs 1 through 56 above are re-alleged and incorporated by reference as if
fully set forth herein.
65. Section 21(d)(5) of the Exchange Act states, “In any action or proceeding brought
or instituted by the Commission under any provision of the securities laws, the Commission may
seek, and any Federal court may grant, any equitable relief that may be appropriate or necessary
for the benefit of investors.”
66. Relief Defendant Corcoran received ill-gotten funds by means of Defendants’
fraudulent conduct in selling securities to investors.  Relief Defendant has no legitimate claim to
this property.  In equity and good conscience, Relief Defendant should not be allowed to retain
such funds.
67. As a result, Relief Defendant is liable for unjust enrichment and should be
required to return her ill-gotten gains, in an amount to be determined by the Court.  The Court
should also impose a constructive trust on the ill-gotten gains in the possession of Relief
Defendant.
PRAYER FOR RELIEF
 WHEREFORE, the Commission respectfully requests that this Court:
 A. Permanently restrain Defendants, their agents, servants, employees and attorneys,
and those persons in active concert or participation with them who receive actual notice of the
injunction by personal services or otherwise, and each of them, from violating Section 10(b) of
the Exchange Act [15 U.S.C. §§78j(b)] and Rule 10b-5 thereunder [17 C.F.R §240.10b-5] by
using any means or instrumentality of interstate commerce, or of the mails, or of any facility of
any national securities exchange, in connection with the purchase or sale of any security:
 (a) to
employ any device, scheme, or artifice to defraud; (b) to make any untrue statement of a material

18

fact, or to omit to state a material fact necessary in order to make the statements made, in the
light of the circumstances under which they were made, not misleading; or (c) to engage in any
act, practice, or course of business which operates or would operate as a fraud or deceit upon any
person by, directly or indirectly, (i) creating a false appearance or otherwise deceiving any
person, or (ii) disseminating false or misleading documents, materials, or information or making,
either orally or in writing, any false or misleading statement in any communication with any
investor or prospective investor, about: (A) any investment strategy or investment in securities,
(B) the prospects for success of any product or company,
 (C) the use of investor funds, (D)
compensation to any person, (E) Defendant’s qualifications to advise investors; or (F) the
misappropriation of investor funds or investment proceeds.
 B. Permanently restrain Defendants, their agents, servants, employees and attorneys,
and those persons in active concert or participation with them who receive actual notice of the
injunction by personal services or otherwise, and each of them, from violating Section 17(  a) of
the Securities Act [15 U.S.C. §§77q(a)], by using any means or instrumentality of interstate
commerce, or of the mails, or of any facility of any national securities exchange, in the offer or
sale of any security:
 (a) to employ any device, scheme, or artifice to defraud; (b) to obtain money
or property by means of any untrue statement of a material fact, or any omission of a material
fact necessary in order to make the statements made, in the light of the circumstances under
which they were made, not misleading; or
 (c) to engage in any transaction, practice, or course of
business which operates or would operate as a fraud or deceit upon the purchaser by, directly or
indirectly, (i) creating a false appearance or otherwise deceiving any person, or (ii) disseminating
false or misleading documents, materials, or information or making, either orally or in writing,
any false or misleading statement in any communication with any investor or prospective

19

investor, about: (A) any investment strategy or investment in securities, (B) the prospects for
success of any product or company, (C) the use of investor funds, (D) compensation to any
person, (E) Defendant’s qualifications to advise investors; or (F) the misappropriation of investor
funds or investment proceeds.
C. Order Defendants and Relief Defendant to disgorge, with prejudgment interest,
their ill-gotten gains obtained by reason of the unlawful conduct alleged in this Complaint,
pursuant to Section 21(d)(5) and (7) of the Exchange Act [15 U.S.C. §78u(d)(5), (7)];
D. Order Defendants each to pay an appropriate civil monetary penalty pursuant to
Section 20(d) of the Securities Act [15 U.S.C. §77t(d)] and Section 21(d)(3) of the Exchange Act
[15 U.S.C. §78u(d)(3)];
E. Retain jurisdiction over this action to implement and carry out the terms of all
orders and decrees that may be entered; and
F. Grant such other further relief as the Court may deem just and proper.
JURY DEMAND
 The Commission demands a jury in this matter for all claims so triable.
DATED: May 15, 2025
      Respectfully submitted,
      /s/ Kathleen Burdette Shields
      Kathleen Burdette Shields (BBO# 637438)
      Heidi Mitza (BBO# 647909)
      SECURITIES AND EXCHANGE COMMISSION
      Boston Regional Office
      33 Arch Street, 24th Floor
      Boston, MA 02110
      Phone: (617) 573-8904 (Shields direct)
      (617) 573-8929 (Mitza direct)
(617) 573-4590 (fax)
      [email protected]
 (Shields email)
      [email protected] ( Mitza email)

UNITED STATES DISTRICT COURT 
DISTRICT OF MASSACHUSETTS 

 
SECURITIES AND EXCHANGE 
COMMISSION, 
   Plaintiff, 
 v. 
 
CHRISTOPHER AUBIN, ANCHOR 
STATE CAPITAL LLC, f/k/a ANCHOR 
STATE INVESTMENTS LLC, and 
ANCHOR STATE PROPERTIES LLC, 
   Defendants, 
 

and 
                                                                     
ASHLEY CORCORAN, 
                                  Relief Defendant. 

 
 
      Civil Action No. 25-CV- 
 
 
 

 
COMPLAINT 

 Plaintiff, Securities and Exchange Commission (the “Commission”), alleges the 

following against defendants Christopher Aubin (“Aubin”), Anchor State Capital LLC, formerly 

known as Anchor State Investments LLC, and Anchor State Properties LLC (collectively with 

Aubin, “Defendants”) and Relief Defendant Ashley Corcoran (“Corcoran”): 

SUMMARY 

1. This case involves the misappropriation and misuse of investor assets by Aubin 

and his companies, Anchor State Capital LLC and Anchor State Properties LLC.  Together, 

Anchor State Capital LLC, formerly known as Anchor State Investments LLC, and Anchor State 

Properties LLC will be referred to as “Anchor State.”  Defendants engaged in a fraudulent 

scheme and made and used false and misleading statements in connection with the sale of 

Anchor State securities.  In total, the Commission estimates that Defendants raised over $2.5 

million from at least 24 investors between at least April 2023 and at least December 2024 (the 

“Relevant Period”).   

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2. As part of their scheme to defraud, Defendants issued Anchor State securities to 

investors in the form of “Investment Contracts,” “Real Estate Partner Contracts,” or “Partner 

Contracts.”  These contracts, typically signed by Anchor State and by each investor, promised 

investors that: (1) Anchor State would use money invested with Anchor State to make short-

term, high-interest rate loans to borrowers as an alternative to traditional financing; (2) some of 

Anchor State’s loans were “hard money” loans, meaning that they were secured by the value of 

the underlying property for which the loan was being provided and Anchor State would repay the 

loans if the borrower defaulted; (3) the loan proceeds would be used solely to finance specific 

loans made to Anchor State borrowers; and (4) investors would be repaid their principal and their 

investment profit when the investment contracts matured, from the principal and interest 

payments made by the loan borrowers. 

3. In truth, Defendants made very few real loans to borrowers and instead used 

investors’ funds largely to make payments to earlier investors and to pay for Defendants’ own 

business expenses and the personal expenses of Aubin and Relief Defendant Corcoran.  Those 

personal expenses included lavish meals, luxury travel and vehicles.  Defendants’ scheme thus 

has many hallmarks of a Ponzi scheme. 

4. In the course of soliciting investments, and lulling investors who were inquiring 

about why they had not been repaid when their investments matured, Defendants made numerous 

false and/or misleading statements to investors.  Defendants misrepresented: the uses to which 

investors’ money had been put, the existence and status of the loans for which the investments 

were purportedly made, the purported reasons why Defendants could not repay the loans when 

they were due, and the nature and success of Defendants’ business. 

5. Defendants were able to keep the scheme going longer than it may otherwise have 

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lasted because they were able to convince some investors to roll over the principal and promised 

interest from maturing investment contracts into new investment contracts with a higher balance.  

Defendants were thus able to avoid the need to make payments on some investment contracts 

when they were originally due. 

6. In mid-2024, however, Defendants were sued in state court by two investors 

whose investment contracts had matured but had not been repaid in full.  Other investors who 

were in a similar position joined in that lawsuit in December 2024.  

7. As of the date of this Complaint, Defendants have failed to repay at least $2 

million in investment principal to investors with matured investment contracts.   This sum does 

not account for the investment returns that Defendants promised to these investors. 

8. As a result of the conduct alleged herein, Defendants violated, and unless 

restrained and enjoined will continue to violate, Section 10(b) of the Securities Exchange Act of 

1934 (“Exchange Act”) and Rule 10b-5 thereunder [15 U.S.C. §78j(b); 17 C.F.R. §240.10b-5] 

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

Relief Defendant Corcoran received proceeds of Defendants’ fraud, which in equity she is not 

entitled to retain. 

9. Based on these violations, the Commission seeks from Defendants: (1) permanent 

injunctions enjoining them from engaging in the transactions, acts, practices, and courses of 

business of the type alleged in this Complaint in violation of the federal securities laws; (2) 

disgorgement of ill-gotten gains from the unlawful conduct set forth in this Complaint pursuant 

to Sections 21(d)(5) and (7) of the Exchange Act [15 U.S.C. §78u(d)(5), (7)], together with 

prejudgment interest; (3) civil penalties pursuant to Section 20(d) of the Securities Act [15 

U.S.C. §77t(d)] and Section 21(d)(3) of the Exchange Act [15 U.S.C. §78u(d)(3)], and such other 

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relief as the Court may deem appropriate. 

10. The Commission also seeks, against Relief Defendant Corcoran, disgorgement of 

her ill-gotten gains together with prejudgment interest thereon, and such other relief as the Court 

may deem appropriate. 

JURISDICTION AND VENUE 

11. This Court has jurisdiction over this action pursuant to Sections 20(d)(1) and 

22(a) of the Securities Act [15 U.S.C. §77t(d)(1), 77v(a)] and Sections 21(d), 21(e), and 27 of the 

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

12. Venue is proper in this Court pursuant to Section 22 of the Securities Act [15 

U.S.C. §77v(a)] and Section 27 of the Exchange Act [15 U.S.C §78aa].  Defendant Aubin 

resided in the District of Massachusetts during the Relevant Period.  Also, certain of the acts, 

practices, transactions and courses of business constituting the violations alleged in this 

Complaint occurred within the District of Massachusetts, and were effected, directly, or 

indirectly, by making use of the means or instrumentalities of transportations or communication 

in interstate commerce, or the mails, including the internet and the telephone.  Some of Anchor 

State’s investors reside in the District of Massachusetts. 

13. Defendants’ conduct involved fraud, deceit, or deliberate or reckless disregard of 

regulatory requirements, and resulted in substantial loss, or significant risk of substantial loss, to 

other persons. 

DEFENDANTS AND RELIEF DEFENDANT 

14. On information and belief, Christopher Aubin, age 30, currently resides in 

Walpole, Massachusetts, and he resided in Walpole during a portion of the Relevant Period.  

During a portion of the Relevant Period, Aubin may have resided in Lincoln, Rhode Island.  

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Aubin is the owner and CEO of both Anchor State entities.  Aubin served in the U.S. Marine 

Corps. 

15. Anchor State Capital LLC, formerly known as Anchor State Investments LLC, is 

a Rhode Island corporation with a principal place of business in Providence, Rhode Island.  It 

was incorporated on May 11, 2023, and changed its name to Anchor State Capital LLC on 

September 30, 2024.  Of the presently-known investors in this scheme, all but two investors were 

issued investment contracts in the name of Anchor State Investments LLC.  At all relevant times, 

Aubin has exercised control over Anchor State Capital LLC and has run all aspects of its 

business. 

16. Anchor State Properties LLC is a Rhode Island corporation with a principal place 

of business in Providence, Rhode Island.  It was incorporated on October 7, 2024.  Of the 

presently-known investors, two were issued investment contracts in the name of Anchor State 

Properties LLC and another made his investment payment to Anchor State Properties LLC.  At 

all relevant times, Aubin has exercised control over Anchor State Properties LLC and has run all 

aspects of its business. 

17. Ashley Corcoran, age 27, resides, on information and belief, in Attleboro, 

Massachusetts and may have lived, at times, with Aubin in Walpole, Massachusetts.  During at 

least part of the Relevant Period, Corcoran was romantically involved with Aubin.    

FACTUAL ALLEGATIONS 

Aubin’s and Anchor State’s Purported Business 

18. On its website, at least on or about June 22, 2024, Anchor State advertised itself 

as providing “Access To Capital When You Need It,” and further said that it both provided 

lending services to borrowers and provided “Tailored Financial Planning from Accredited 

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Professionals” under a heading of “Planning Futures and Investing.”  One of the “Frequently 

Asked Questions” was “How Can I Determine Which Investment Opportunity is Right for Me?” 

19. By September 21, 2024, the “About Us” tab of Anchor State’s website 

represented that Anchor State is “Your Trusted Partner in Financial Success,” and listed 

attributes of “Investing with Anchor State,” including stability, cash flow, amortization, tax 

benefits, leverage and appreciation, which were all focused on investments in real estate.  Under 

another “Private Lending” tab, the website described its private lending business as involving 

“hard money lending” that could be available for borrowers “whether you’re looking to fund a 

new investment venture, undertake a home renovation project, cover unexpected expenses, or 

consolidate debt.”  Anchor State also stated that another aspect of its business was buying houses 

from individuals, “No Matter The Condition.” 

20. Aubin described his Anchor State business to numerous investors as a short-term, 

“hard money” lending company that made loans to borrowers for property-related financing 

projects, real estate investments or other business-related purposes.  A “hard money” loan is a 

secured loan based on a property’s value rather than loans based on the borrower’s credit 

worthiness.  Aubin also told several investors that Anchor State made money on the points and 

other fees that borrowers paid to get a loan from Anchor State, and that investors would make 

money by selecting one or more of the loans to finance, and their investment return would be the 

interest that the borrower paid to Anchor State.   

21. Aubin told investors that they could choose which particular projects or loans they 

would like to finance with their investment principal.  The investors’ role was passive; they 

expected to profit from Defendants’ efforts.  Aubin, and others working with him, typically gave 

investors and potential investors lists of loans that were available for financing.  Those lists 

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contained information concerning the particular projects to which Anchor State could lend the 

investor’s funds, including terms such as the length of the loan, the interest rate, the points the 

loan would carry, and the purpose of the loan.  An excerpt of one of these available loan lists 

appears below: 

 

22. To memorialize investors’ investments, Anchor State provided investors with a 

contract.  These contracts, which for different investors were titled “Investment Contracts,” 

“Partner Contracts,” and/or “Real Estate Partner Contracts,” had generally similar terms and 

were typically signed both by Anchor State and by the investor.   

23. Anchor State’s investment contracts stated that investors would receive returns of 

between 12% and 19% for investments lasting between one month and eight months.   

24. The investment contracts typically stated that Anchor State was “engaged in the 

business of LENDING (e.g. expansion, construction flips, hard money, real-estate purchases, 

etc.),” stated that Anchor State “desires to use the Investor’s funds to fund this event in 

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consideration for the items listed in this Agreement,” and provided that “[n]o other expenses may 

be paid for with the Funds the Investor provides the Company.”   

25. The investment contracts each matured on a specified date (usually between one 

and eight months in the future) and typically provided that investors would be repaid their 

principal plus their investment return when the investment matured.  Several investment 

contracts provided that investors would be paid monthly interest, with the principal to be repaid 

when the investment matured.   

26. The investment contracts offered by Defendants between July 2023 and early 

June 2024 also promised that, if the loan to finance the selected project defaulted, Anchor State 

would back the investor with its own equity, assets, and funds.  The investment contracts offered 

in June 2024 and July 2024 provided that, in the event of a default, Anchor State would “work in 

a timely manner to return principal to investor.”  After July 2024, the provisions about what 

would happen in the event of a default were removed (except as to one investor who had made 

multiple investments dating back to November 2023).  

27. Investors typically transferred their investment funds to Anchor State by check, 

wire transfer, or, in a few instances, by giving cash to Aubin. 

28. Aubin’s sales pitch to potential investors included his trustworthiness as a Marine 

Corp veteran.  At least two of Defendants’ investors were Marine Corps veterans who had served 

with Aubin. 

29. Relief Defendant Corcoran performed some work for Anchor State.  She 

responded to inquiries by some investors when their investment funds were not repaid when 

those funds were due.   

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30. To date, the Commission has identified at least 24 investors who invested with 

Anchor State during the Relevant Period.  Those 24 investors invested over $2.5 million with 

Anchor State.   

Examples of Specific Investments 

31. Investor 1 entered into a “Real Estate Partner Contract” with Anchor State on 

August 26, 2024, pursuant to which he invested $50,000.  The contract promised Investor 1 a 

return of 12% for an investment that would mature in approximately one month, on September 

30, 2024.  Thus, Investor 1 expected to be repaid $56,000.  In verbal discussions, Aubin told 

Investor 1 that his money would be used for a hard money loan that would serve as the down 

payment for land and that Anchor State was in “first position” with respect to the land.   

32. When Investor 1’s investment matured, Aubin told Investor 1 that the land deal 

had closed and he had the money to repay Investor 1.  Aubin sent Investor 1 a purported 

screenshot from his bank system that showed a wire transfer of $56,000 was processing.  This 

screenshot appears to have been fabricated.  The wire transfer did not arrive in Investor 1’s bank 

account and Aubin told Investor 1 that he had changed banks and there was a problem because 

his account had been flagged.  Aubin then promised to send Investor 1 a check.  The check never 

arrived.   

33. At the time of Investor 1’s investment, Anchor State maintained bank accounts at 

TD Bank, N.A. (“TD Bank”).  Aubin was the sole authorized signatory on Anchor State’s bank 

accounts. 

34. Anchor State’s bank records show that Investor 1’s funds were not used to make 

investments, contrary to the representations in the Real Estate Partner Contract.  Rather, a 

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portion of Investor 1’s funds were used to fund payments to another investor and certain 

unknown individuals; another portion was transferred to Aubin’s personal account. 

35. Investor 2 entered into an “Investment Contract” with Anchor State on January 4, 

2024, pursuant to which he wired $145,500 to Anchor State’s bank account.  This investment 

was supposed to mature three months later, on April 4, 2024.  Before Investor 2 entered into this 

Investment Contract, Anchor State sent Investor 2 a list of “Loans for investment as of January 

2nd, 2024,” which contained information concerning the particular projects to which Anchor 

State could lend Investor 2’s funds, including terms, such as the length of the loan, the interest 

rate, the points it would carry, and the purpose of the loan.  Investor 2 chose to invest in projects 

that were described as “driveway in Smithfield,” “septic system putnam,” “lot clearing in foster,” 

“land clearing cumberland,” and “[a]ddition in warwick RI,” and Anchor State provided him 

with an account statement listing the loans he had chosen to finance and stating that Anchor State 

owed him a total of $171,553.75 in principal and profit on his investment.  This list of loans 

provided by Anchor State indicated that each of these loans carried an interest rate of between 

17.5% and 18%.   

36. When Investor 2’s Investment Contract matured, he requested payment from 

Aubin.  Aubin promised to pay him promptly, but then provided a series of excuses for why he 

could not repay Investor 2.   

37. At the time of Investor 2’s investment, Anchor State maintained bank accounts at 

TD Bank.  Aubin was the sole authorized signatory on Anchor State’s bank accounts. 

38. Anchor State’s bank records show that it made two payments to Investor 2 

totaling $29,345: one wire payment of $26,845 on April 23, 2024 and one check for $2,500 dated 

May 1, 2024.  In addition, Aubin left a check for Investor 2 and other investors at a business 

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owned by another investor.  When Investor 2 attempted to deposit that check in the amount of 

$144,708.75 from Anchor State, which was dated May 9, 2024, the check bounced.  At the time 

Aubin provided this check to Investor 2, he knew or was reckless in not knowing it would 

bounce because Anchor State’s accounts were not even close to containing sufficient funds to 

pay it. 

39. Since that time, Investor 2 has received no other payments from Aubin or Anchor 

State.  Investor 2 continues to contact Aubin to seek payment and Aubin gives him a variety of 

excuses about why Aubin and Anchor State cannot pay, including that he had repaid some other 

investors, that he had gotten in over his head with a social media influencer circle and could not 

handle his business, that he had problems caused by a lawsuit filed by several investors and that 

an attorney had taken his money.   

40. Anchor State bank records show that Investor 2’s funds were not used to make the 

five loans contemplated by his investment contract.  Rather, those bank records show that 

Investor 2’s funds were combined with funds from another investor, and were used to fund a 

large ($294,629) transfer to a title and closing company, as well as transfers to another investor 

and other individuals, two cash withdrawals, and two transfers of funds to Aubin’s personal 

account. 

41. Investor 3 entered into a “Partner Contract” with Anchor State on June 24, 2024, 

pursuant to which she invested $85,000.  The contract promised Investor 3 a return of 19% for an 

investment that would mature in approximately three months, on September 20, 2024.  Thus, 

Investor 1 expected to be repaid $101,150.  Before her investment, Anchor State sent Investor 3 

a list of projects in which she could invest.  Investor 3 understood, based on her discussions with 

Aubin and the language in her Partner Contract, that her investment would be used only to 

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finance the two projects that she had selected from Anchor State’s list of loans that were 

available for investment.   

42. To pay for her investment, Investor 3 wrote a check for $85,000 on her 

company’s account at BayCoast Bank.  Aubin personally collected the check from Investor 3 on 

June 24, 2024.  Investor 3 made the check out to Aubin personally but wrote “Anchor State 

AM01-02” in the check’s memo line, which was a reference to the numbers of the two projects 

in which she chose to invest.   

43. Later in the day on June 24, 2024, Aubin took Investor 3’s check to BayCoast 

Bank and cashed the check.  Aubin received a $75,000 bank check and $10,000 in cash.  He then 

immediately used $55,000 of the $75,000 check to open a personal account in his own name at 

BayCoast Bank and took out another $20,000 in cash.  Later that day, Aubin went to a different 

BayCoast Bank branch and withdrew $7,000 in cash and paid his attorney $8,000 from his new 

personal account, leaving a $40,000 balance.  The next morning, June 25, 2024, Aubin paid 

another investor $24,570 from his BayCoast personal account by check.  Later that day, Aubin 

went to a third BayCoast Bank branch and withdrew the remaining $15,430 in the form of a bank 

check for $10,000 (plus a $5 fee) and $5,425 in cash and closed his personal account at 

BayCoast Bank.  Thus, Aubin did not use Investor 3’s investment funds to finance two projects 

as Defendants had promised.  Rather, Aubin used her funds to repay another investor and for his 

own personal and/or business expenses. 

44. When Investor 3’s loan was about to mature, Aubin asked Investor 3 if she would 

like to roll over her investment into another project.  Investor 3 decided to withdraw her 

investment in cash.  Aubin gave Investor 3 various excuses about why she was not being repaid.  

Aubin sent Investor 3 a Fund Withdrawal Form so that Anchor State could repay her investment 

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by wire transfer.  Investor 3 completed and returned that form to Defendants but was not repaid.  

45. Throughout the fall of 2024, Investor 3 spoke to Aubin about weekly.  On 

multiple occasions, Aubin told Investor 3 that she would be repaid within a few days but the 

repayments were never forthcoming and he would give her excuses as to why the payments were 

not made.  Those excuses related to aspects of Aubin’s personal life and his tax obligations.   

46. To date, Defendants have not repaid any of Investor 3’s principal or promised 

investment income. 

Aubin and Anchor State Misrepresented the Uses of Investors’ Funds and their Conduct is 
Characteristic of a Ponzi Scheme 
 

47. Defendants’ representations that investors’ funds would be used only to provide 

loans to Anchor State borrowers and would not be used for other purposes were, in many 

instances, false and misleading.  At the time they made these representations, Aubin and Anchor 

State knew, or had reason to know, or were reckless in not knowing, that the money invested by 

their investors was not, and would not be, used to fund the loans that were described in the 

investors’ investment contracts.  Anchor State’s bank records show few, if any, disbursements of 

funds in dates or amounts that match the loans that were described in the investors’ investment 

contracts.  Further, Anchor State’s bank records do not show repayments from borrowers to 

Anchor State. 

48. Instead, Anchor State’s bank records show a pattern of investors’ funds being 

disbursed shortly after they were deposited to fund, among other things:  1) payments to other 

investors whose investment contracts had matured, 2) payments to personal bank accounts 

belonging to Aubin, 3) cash withdrawals, and 4) payments to various entities for Aubin’s and/or 

Corcoran’s living expenses and luxury travel. 

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49. The use of later investors’ funds to repay earlier investors whose investments had 

matured is characteristic of a Ponzi scheme. 

50. In addition, Aubin solicited certain investors to “roll over” their principal and 

investment return into a subsequent investment, i.e. decline to take the payout and instead 

directly reinvest the proceeds in the scheme.  Such an approach is characteristic of a Ponzi 

scheme because it allows the operator of the Ponzi scheme to avoid needing to make a payout, 

thereby keeping investor funds under his or her control. 

51. Many Anchor State investors whose investment contracts have matured have not 

been repaid either their principal or promised investment return.  Based on the information 

available to the Commission, Aubin and Anchor State took in at least $2 million more in investor 

deposits than they have repaid to investors. 

Relief Defendant Corcoran Benefitted Financially From Defendants’ Fraud 

52. Aubin and Anchor State transferred proceeds from their fraudulent investment 

scheme to Relief Defendant Corcoran for no legitimate purpose or consideration. 

53. On information and belief, on or about February 7, 2024, Aubin spent about 

$66,805 from Anchor State’s bank accounts to purchase a BMW automobile.  Aubin then gave 

that automobile to Corcoran for her personal use.  Corcoran thus received a personal benefit to 

which she was not entitled. 

54. On numerous occasions in 2023 and 2024, funds from Anchor State’s bank 

accounts were used to pay for luxury travel, including private jet transport, for Aubin and 

Corcoran.  Corcoran thus received a personal benefit from these gifts of travel to which she was 

not entitled. 

55. On April 23, 2024, Aubin transferred $20,000 from one of Anchor State’s bank 

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accounts to his personal bank account and then, the same day, withdrew $15,000 from that 

personal account in the form of a bank check made payable to Corcoran’s mother with a notation 

on the check that it was “Re: Ashley E. Corcoran.”  On information and belief, Corcoran thus 

received a personal benefit from this indirect withdrawal from Anchor State’s bank account to 

which she was not entitled. 

56. Between about October 28 and December 10, 2024, a total of $22,400 was 

transferred from Anchor State Properties’ bank account to a personal account jointly owned by 

Aubin and Corcoran at Bank of America.  On information and belief, Corcoran received a 

personal benefit from the expenditure of the funds in the bank account she jointly owned with 

Aubin.  

FIRST CLAIM FOR RELIEF 
FRAUD IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES  

 
Defendants’ Violations of Section 10(b) of the Exchange Act and Rule 10b-5 thereunder 

 
57. Paragraphs 1 through 56 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

58. By reason of the conduct described above, Defendants, directly or indirectly, in 

connection with the purchase or sale of securities, by the use of the means or instrumentalities of 

interstate commerce or of the mails, or of any facility of any national securities exchange, 

intentionally, knowingly, or recklessly, (i) employed devices, schemes, or artifices to defraud; 

(ii) made untrue statements of material facts or omitted to state material facts necessary to make 

the statements made, in the light of the circumstances under which they were made, not 

misleading; and/or (iii) engaged in acts, practices, or courses of business which operated or 

would operate as a fraud or deceit upon any persons, including purchasers or sellers of the 

securities. 

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59. Defendants’ conduct involved fraud, deceit, manipulation or deliberate or reckless 

disregard of regulatory requirements and directly or indirectly resulted in substantial losses to 

other persons. 

60. By reason of the conduct described above, Defendants violated Exchange Act 

Section 10(b) [15 U.S.C. §78j(b)] and Rule 10b-5 [17 C.F.R §240.10b-5] thereunder. 

SECOND CLAIM FOR RELIEF 
FRAUD IN THE OFFER OR SALE OF SECURITIES 

 
Defendants’ Violations of Sections 17(a) of the Securities Act  

 
61. Paragraphs 1 through 56 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

62. By reason of the conduct described above, Defendants, directly or indirectly, in 

connection with the offer or sale of securities, by the use of the means or instrumentalities of 

interstate commerce or of the mails, directly or indirectly, acting intentionally, knowingly, 

recklessly, or negligently: (i) employed devices, schemes, or artifices to defraud; (ii) obtained 

money or property by means of untrue statements of material fact or by omitting to state material 

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

they were made, not misleading; or (iii) engaged in transactions, practices, or courses of business 

which operated or would operate as a fraud or deceit upon any persons, including purchasers or 

sellers of the securities. 

63. By reason of the conduct described above, Defendants violated Securities Act 

Sections 17(a) [15 U.S.C. §77q(a)] and will continue to violate that section unless enjoined. 

THIRD CLAIM FOR RELIEF 
OTHER EQUITABLE RELIEF, INCLUDING  

UNJUST ENRICHMENT AND CONSTRUCTIVE TRUST 
 

As to Relief Defendant Corcoran 

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64. Paragraphs 1 through 56 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

65. Section 21(d)(5) of the Exchange Act states, “In any action or proceeding brought 

or instituted by the Commission under any provision of the securities laws, the Commission may 

seek, and any Federal court may grant, any equitable relief that may be appropriate or necessary 

for the benefit of investors.” 

66. Relief Defendant Corcoran received ill-gotten funds by means of Defendants’ 

fraudulent conduct in selling securities to investors.  Relief Defendant has no legitimate claim to 

this property.  In equity and good conscience, Relief Defendant should not be allowed to retain 

such funds.   

67. As a result, Relief Defendant is liable for unjust enrichment and should be 

required to return her ill-gotten gains, in an amount to be determined by the Court.  The Court 

should also impose a constructive trust on the ill-gotten gains in the possession of Relief 

Defendant.  

PRAYER FOR RELIEF 

 WHEREFORE, the Commission respectfully requests that this Court: 

 A. Permanently restrain Defendants, their agents, servants, employees and attorneys, 

and those persons in active concert or participation with them who receive actual notice of the 

injunction by personal services or otherwise, and each of them, from violating Section 10(b) of 

the Exchange Act [15 U.S.C. §§78j(b)] and Rule 10b-5 thereunder [17 C.F.R §240.10b-5] by 

using any means or instrumentality of interstate commerce, or of the mails, or of any facility of 

any national securities exchange, in connection with the purchase or sale of any security: (a) to 

employ any device, scheme, or artifice to defraud; (b) to make any untrue statement of a material 

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18 
 

fact, or to omit to state a material fact necessary in order to make the statements made, in the 

light of the circumstances under which they were made, not misleading; or (c) to engage in any 

act, practice, or course of business which operates or would operate as a fraud or deceit upon any 

person by, directly or indirectly, (i) creating a false appearance or otherwise deceiving any 

person, or (ii) disseminating false or misleading documents, materials, or information or making, 

either orally or in writing, any false or misleading statement in any communication with any 

investor or prospective investor, about: (A) any investment strategy or investment in securities, 

(B) the prospects for success of any product or company, (C) the use of investor funds, (D) 

compensation to any person, (E) Defendant’s qualifications to advise investors; or (F) the 

misappropriation of investor funds or investment proceeds.  

 B. Permanently restrain Defendants, their agents, servants, employees and attorneys, 

and those persons in active concert or participation with them who receive actual notice of the 

injunction by personal services or otherwise, and each of them, from violating Section 17(a) of 

the Securities Act [15 U.S.C. §§77q(a)], by using any means or instrumentality of interstate 

commerce, or of the mails, or of any facility of any national securities exchange, in the offer or 

sale of any security: (a) to employ any device, scheme, or artifice to defraud; (b) to obtain money 

or property by means of any untrue statement of a material fact, or any omission of a material 

fact necessary in order to make the statements made, in the light of the circumstances under 

which they were made, not misleading; or (c) to engage in any transaction, practice, or course of 

business which operates or would operate as a fraud or deceit upon the purchaser by, directly or 

indirectly, (i) creating a false appearance or otherwise deceiving any person, or (ii) disseminating 

false or misleading documents, materials, or information or making, either orally or in writing, 

any false or misleading statement in any communication with any investor or prospective 

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19 
 

investor, about: (A) any investment strategy or investment in securities, (B) the prospects for 

success of any product or company, (C) the use of investor funds, (D) compensation to any 

person, (E) Defendant’s qualifications to advise investors; or (F) the misappropriation of investor 

funds or investment proceeds.  

C. Order Defendants and Relief Defendant to disgorge, with prejudgment interest, 

their ill-gotten gains obtained by reason of the unlawful conduct alleged in this Complaint, 

pursuant to Section 21(d)(5) and (7) of the Exchange Act [15 U.S.C. §78u(d)(5), (7)]; 

D. Order Defendants each to pay an appropriate civil monetary penalty pursuant to 

Section 20(d) of the Securities Act [15 U.S.C. §77t(d)] and Section 21(d)(3) of the Exchange Act 

[15 U.S.C. §78u(d)(3)]; 

E. Retain jurisdiction over this action to implement and carry out the terms of all 

orders and decrees that may be entered; and  

F. Grant such other further relief as the Court may deem just and proper. 

JURY DEMAND 

 The Commission demands a jury in this matter for all claims so triable. 

DATED: May 15, 2025 

      Respectfully submitted, 

      /s/ Kathleen Burdette Shields    
      Kathleen Burdette Shields (BBO# 637438)  
      Heidi Mitza (BBO# 647909) 
      SECURITIES AND EXCHANGE COMMISSION 
      Boston Regional Office 
      33 Arch Street, 24th Floor 
      Boston, MA 02110 
      Phone: (617) 573-8904 (Shields direct) 
      (617) 573-8929 (Mitza direct) 

(617) 573-4590 (fax) 
      [email protected] (Shields email) 
      [email protected] (Mitza email) 

Case 1:25-cv-11379     Document 1     Filed 05/15/25     Page 19 of 19

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