2026-04-02 sec-litreleases complaint 227 KB 32,150 chars

SEC v. Personal Representative of the Estate of John R. Brodacki, III; and Castle Hill Financial Group, LLC, No. 3:26-cv-30055, District of Massachusetts (Apr. 2, 2026) — Complaint

raw: SEC v. PERSONAL REPRESENTATIVE OF

SEC v. PERSONAL REPRESENTATIVE OF, No. 3:26-cv-30055 (Apr. 2, 2026)

Caption: Securities and Exchange Commission v. Personal Representative of the Estate of John R. Brodacki, III

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

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Enriched metadata

Scheme: ponzi (98%)
Court: District of Massachusetts
Case No.: 3:26-cv-30055
Victim loss: $24,500,000
Entity: Castle Hill Financial Group, LLC

Classified ponzi(confidence 98%). EDGAR detection: forms Form D· recall 35% / precision 15%. detection rule →

Extracted insights

Dollar amounts 50

$24.50M $24.5 million $10M–$100M
$1.84M $1.84 million $1M–$10M
$1.80M $1.8 million $1M–$10M
$1.68M $1.68 million $1M–$10M
$300K $300,000 $100K–$1M
$300K $300,000 $100K–$1M
$225K $225,000 $100K–$1M
$163K $162,750 $100K–$1M
$127K $127,000 $100K–$1M
$124K $124,000 $100K–$1M
$108K $108,000 $100K–$1M
$100K $100,000 $100K–$1M

Entities 1

person those funds

Triples 9

Brodacki and Castle Hill obtained over $1.8 million from at least 18 advisory clients between June 2018 and September 2025
Brodacki and Castle Hill fraudulently induced at least 18 advisory clients to transfer money to Castle Hill
Brodacki and Castle Hill misappropriated those funds
Brodacki and Castle Hill used the funds to pay Brodacki’s personal and business expenses
Brodacki and Castle Hill provided advisory clients with fabricated account statements
Commission estimates that Brodacki and Castle Hill misappropriated approximately $1.68 million
Commission seeks permanent injunctions from Castle Hill
Commission seeks civil penalties from Castle Hill
Commission seeks disgorgement of ill-gotten gains from the Estate and Castle Hill

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SEC v. PERSONAL REPRESENTATIVE OF · Source

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Extracted body text (32,150c)

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

SECURITIES AND EXCHANGE
COMMISSION,
Plaintiff,
v.

PERSONAL REPRESENTATIVE OF
THE ESTATE OF JOHN R. BRODACKI,
III and CASTLE HILL FINANCIAL
GROUP, LLC,

Defendants.

Civil Action No. 26-CV-

COMPLAINT

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

following against defendants the Personal Representative of the Estate of John R. Brodacki, III

(the “Estate”), and Castle Hill Financial Group, LLC (“Castle Hill”):

SUMMARY

1. This suit arises from the actions of John R. Brodacki, III (“Brodacki”), prior to his

death on or about March 23, 2026. Brodacki and his company, Castle Hill were investment

advisers who owed fiduciary duties to their advisory clients. Brodacki and Castle Hill breached

those fiduciary duties by engaging in a fraudulent scheme, using deceptive devices, and making

and using false and misleading statements to misappropriate and misuse money from certain of

their advisory clients. In total, the Commission estimates that Brodacki and Castle Hill obtained

over $1.8 million to which they were not entitled from at least 18 of their advisory clients

between at least June 2018 and September 2025 (the “Relevant Period”).

2. Brodacki and Castle Hill fraudulently induced at least 18 of their advisory clients,

many of whom were elderly, retired or seriously ill, to transfer money to Castle Hill. Brodacki

told these advisory clients that their funds would be used to make investments for their benefit

and/or the benefit of their relatives.

3. Instead of making such investments to benefit the advisory clients and their

relatives, Brodacki and Castle Hill misappropriated those funds, and used the funds to pay

Brodacki’s own personal and business expenses, to make repayments to other advisory clients,

and to make payments to Brodacki’s own family members. Those personal expenses included

lavish meals, membership fees to exclusive social clubs, travel, and tuition for Brodacki’s family

members. Brodacki’s and Castle Hill’s actions thus have some of the hallmarks of a Ponzi

scheme.

4. In furtherance of their scheme, Brodacki and Castle Hill provided some of these

advisory clients with fabricated account statements showing the purported value of the

investments they claim to have made for these clients.

5. Some of these advisory clients sought and obtained partial repayments of the

money they sent to Castle Hill. After deducting those partial repayments of approximately

$162,750, the Commission estimates that Brodacki and Castle Hill misappropriated

approximately $1.68 million from the advisory clients they targeted in their scheme.

6. As a result of the conduct alleged herein, Brodacki and Castle Hill violated, and

unless Castle Hill is restrained and enjoined, it will continue to violate, Sections 206(1) and

206(2) of the Investment Advisers Act of 1940 (“Advisers Act”) [15 U.S.C. §§80b-6(1), (2)].

7. Based on these violations, the Commission seeks from Castle Hill: (1) permanent

injunctions enjoining it 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; and (2) civil

penalties pursuant to Section 209(e) of the Advisers Act [15 U.S.C. §80b-9(e)]. The

Commission seeks from both the Estate and Castle Hill disgorgement of ill-gotten gains from the

unlawful conduct set forth in this Complaint pursuant to Sections 21(d)(5) and (7) of the

Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. §78u(d)(5), (7)], together with

prejudgment interest thereon, and such other relief as the Court may deem appropriate.

JURISDICTION AND VENUE

8. This Court has jurisdiction over this action pursuant to Sections 209(d) and 214 of

the Advisers Act [15 U.S.C. §§80b-9(d), 80b-14].

9. Venue is proper in this Court pursuant to Section 214 of the Advisers Act [15

U.S.C. §80b-14] and 28 U.S.C. §1391(d) because, among other things, certain of the acts,

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

Complaint occurred within the District of Massachusetts, and because Brodacki resided and died

in Massachusetts and Castle Hill’s principal place of business was in Massachusetts during the

Relevant Period.

10. Brodacki and Castle Hill directly or indirectly used the mails or the means or

instruments of transportation or communication in interstate commerce, including the internet

and the telephone, in connection with their business as investment advisers and the conduct

described in this Complaint.

11. Brodacki’s and Castle Hill’s 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

12. Brodacki, age 49 at the time of his death, resided in Longmeadow, Massachusetts.

Brodacki died on or about March 23, 2026. During the Relevant Period, Brodacki was the

founder and CEO of Castle Hill. Brodacki worked in the financial advisory area from 2001 until

the time of his death.

13. During the Relevant Period, Castle Hill was a Massachusetts limited liability

company, solely owned by Brodacki, with a principal place of business in Longmeadow,

Massachusetts. At times during the Relevant Period, Castle Hill also maintained an office in

Newton, Massachusetts. Castle Hill was involuntarily dissolved as a corporation by the

Commonwealth of Massachusetts as of December 31, 2025.

FACTUAL ALLEGATIONS

Defendants’ Business as Investment Advisers

14. From December 2017 until July 11, 2025, Brodacki and Castle Hill were not

directly registered with the Commission as investment advisers. Instead, Brodacki was an

investment adviser representative of a Commission-registered investment advisory firm (the

“Registered Adviser”), and Castle Hill was one of the independent financial advisors through

which the Registered Adviser operated. During that period, Brodacki’s and Castle Hill’s

investment advisory business was supervised by the Registered Adviser and they were subject to

the policies and procedures established by the Registered Adviser.

15. During the period that Brodacki and Castle Hill did business through the

Registered Adviser, they acted as investment advisers to approximately 110 advisory clients and

had approximately $24.5 million in assets under their management.

16. Typically, Brodacki’s and Castle Hill’s relationships with their advisory clients

were documented in “Advisory and Investment Management Agreements” or “Investment

Management Agreements” (collectively “Advisory Agreements”) between the client and the

Registered Adviser d/b/a Castle Hill.

17. Under those Advisory Agreements, clients maintained brokerage accounts with a

large brokerage firm that served as the custodian for their assets (the “Custodian”) and all of their

investment assets were to be invested through their account at the Custodian, where they would

be managed by Brodacki and Castle Hill as their investment advisers. In exchange for those

advisory services, the Advisory Agreements required each client to pay quarterly fees based on

the total amount of their assets under management at the Custodian. Those fees ranged from

.75% annually to 1.25% annually.

18. The Advisory Agreements also stated that “[a]t no time will the Advisor accept,

maintain possession or have custodial responsibility for the Client’s funds or securities.”

19. The Registered Adviser established Compliance Guidelines that its investment

adviser representatives, including Brodacki and Castle Hill, were required to follow. Among

many other compliance rules, Brodacki and Castle Hill were informed that “Clients need to be

aware checks must be made payable to [the Custodian] and that you do not accept checks made

out to yourself or your DBA,” and that “[n]o advisory services, including Financial Planning, can

be paid directly to you or your business DBA.” In addition, the Compliance Guidelines provided

that Brodacki and Castle Hill “are not permitted to borrow or loan money to any clients for any

reason.” The purpose of this policy was to ensure the safety of advisory clients’ funds.

Misconduct by Brodacki and Castle Hill

20. On July 11, 2025, the Registered Adviser terminated Brodacki’s employment and

ended its relationship with Castle Hill. In the public filing it made with the Financial Industry

Regulatory Authority as a result of Brodacki’s termination, the Registered Adviser stated that

Brodacki was terminated for “violation of firm policies and procedures and industry regulations

and conduct.”

21. The Registered Adviser terminated Brodacki’s employment following its

investigation that concluded that Brodacki improperly received funds from one of his clients

directly into a Castle Hill account.

22. Even after the Registered Adviser terminated its relationships with Brodacki and

Castle Hill, Brodacki and Castle Hill continued to solicit and accept client funds for his

purported investment advisory services. He also continued to advertise his and Castle Hill’s

investment advisory services via Castle Hill’s website and claimed it still had a relationship with

the Registered Adviser. This conduct continued until December 2025.

23. Despite the terms of the Advisory Agreements with their clients and the

Registered Adviser’s policy requiring client assets to be held by the Custodian, Brodacki and

Castle Hill fraudulently induced at least 18 of their advisory clients (during the Relevant Period)

to make purported “investments” outside of their Custodian brokerage accounts by sending funds

directly to Castle Hill. Brodacki and Castle Hill promised these 18 advisory clients that they

would use these funds to make various types of investments for the benefit of the clients and/or

their relatives. The clients understood that Brodacki and Castle Hill would manage these

investments as their investment advisers and they never told them otherwise. As examples,

Brodacki and Castle Hill told some clients that they would invest in high-yield bank accounts,

stocks, bonds, certificates of deposit, notes, or in securities of private companies.

24. Brodacki and Castle Hill instructed these clients to send their funds for these

alternative investments by check or by wire transfer payable directly to Castle Hill. Brodacki

and Castle Hill deposited those client funds into two Castle Hill bank accounts that Brodacki

controlled.

25. Rather than making the promised investments, Brodacki and Castle Hill

misappropriated some or all of the money that their advisory clients sent directly to Castle Hill.

Castle Hill’s bank records demonstrate that little to none of the clients’ funds it received for

investment purposes was used to make investments.

26. To date, the Commission has identified at least 18 advisory clients who sent

investment funds directly to Castle Hill during the Relevant Period. Those 18 advisory clients

sent Castle Hill approximately $1.84 million.

27. Brodacki and Castle Hill did not provide most of these 18 advisory clients with

periodic account statements identifying the investments that they had purportedly made with the

funds the advisory clients sent to Castle Hill, the amounts of those investments, or the

performance of those investments. Rather, because of the advisory clients’ longstanding

relationships with Brodacki and Castle Hill, and their trust in Brodacki and Castle Hill, the

advisory clients expected Brodacki and Castle Hill to act in good faith on their behalf.

28. In at least one instance in which an advisory client requested documentation of

their investments through Castle Hill, Brodacki provided that client with fabricated account

statements. These fabricated account statements showed investments that did not exist, and

increases over time in the value of investments that were never made.

29. Through these actions, Brodacki and Castle Hill exploited the trust their advisory

clients placed in them and breached their fiduciary duties to their advisory clients. Most of the

advisory clients had little to no investment experience, and some were retired or seriously ill.

Examples of Misappropriation from Certain Advisory Clients

Advisory Client 1

30. Advisory Client 1 is a retired building contractor, aged 77, who lives on a fixed

income. Advisory Client 1 entered into an Advisory Agreement with the Registered Adviser

(doing business through Castle Hill) on or about June 22, 2019. That Advisory Agreement

contained all of the terms described above. As part of this Advisory Agreement, Advisory Client

1 established brokerage accounts at the Custodian that were managed by Brodacki and Castle

Hill.

31. In the summer of 2022, when Advisory Client 1 was aged 74, Advisory Client 1

had a conversation with Brodacki about wanting to leave $100,000 to his sister when he died.

Brodacki told Advisory Client 1 to send him the money and represented that he would create a

separate account to benefit Advisory Client 1’s sister.

32. Accordingly, Advisory Client 1 sent two checks to Castle Hill, one for $50,000 on

July 18, 2022 and the second for $50,000 on July 21, 2022. These checks were deposited into

Castle Hill’s bank account.

33. Brodacki did not initially tell Advisory Client 1 where the account for his sister

would be established, but Advisory Client 1 assumed it would be held at the Custodian.

34. Beginning by at least February 2023, Brodacki began sending periodic account

detail reports to Advisory Client 1 by email. Advisory Client 1 kept many of those reports,

which arrived monthly, or near monthly. Those account detail reports indicated that, in addition

to accounts at the Custodian, Advisory Client 1 had an account or investment at “New England

Note” that was valued at $100,000 as of February 9, 2023, and an investment at a small private

social media company that was valued at $50,000 on the same date. The beneficiary of the

“New England Note” investment was listed as Advisory Client 1’s sister.

35. The account detail reports indicated that the purported value of the New England

Note investment increased from $100,000 in February 2023, to $108,000 by September 2023, to

$124,000 by December 2024, and to $127,000 by July 2025.

36. On information and belief, the company referred to as “New England Note” in

these account detail statements does not exist.

37. The Castle Hill bank statements indicate that, rather than making an investment

with the $100,000 that Advisory Client 1 entrusted to Brodacki and Castle Hill to invest for his

sister’s benefit, Brodacki and Castle Hill spent that $100,000 to benefit themselves. Specifically,

at the time of Advisory Client 1’s $100,000 deposit to Castle Hill’s bank account, the account

contained about $43,000, and an additional $13,000 was deposited from other sources. Over the

next month, all of those funds were spent or withdrawn leaving a balance of approximately $438.

Expenditures of those funds included: $44,000 in transfers of funds to Brodacki’s personal

account or cash withdrawals, over $24,000 to a home improvement contractor, over $32,000 for

Castle Hill’s rent, over $14,000 to make payments on credit cards and loans, over $8,000 for

dining and entertainment, and over $4,000 for travel.

Advisory Client 2

38. Advisory Client 2 is a retired engineer, aged 73. On information and belief,

Advisory Client 2 is terminally ill. Brodacki and Castle Hill were Advisory Client 2’s

investment adviser for approximately four years. As part of that advisory relationship, Advisory

Client 2 had a brokerage account at the Custodian that was managed by Brodacki and Castle

Hill.

39. In June 2023, Advisory Client 2 consulted with Brodacki about investing some

extra money she had obtained. Advisory Client 2 expressed that she wanted to invested in safe

bank certificates of deposit. Brodacki informed Advisory Client 2 that, instead of buying a bank

certificate of deposit, he would purchase for her investments in non-bank notes or non-bank

bonds that would pay her a substantially higher interest rate than a bank certificate of deposit.

40. Based on that conversation with Brodacki, Advisory Client 2 agreed that Brodacki

would purchase notes or bonds paying 6% or 8% interest for her as an investment. Brodacki told

Advisory Client 2 to send him checks made payable to Castle Hill.

41. On or about June 2, 2023 and again on or about July 29, 2024, Advisory Client 2

sent Castle Hill checks, each in the amount of $10,000, made payable to Castle Hill. Advisory

Client 2 understood that Brodacki and Castle Hill would use this $20,000 to purchase

investments for Advisory Client 2 in notes or bonds paying 6% or 8% interest.

42. Brodacki and Castle Hill did not provide Advisory Client 2 with any paperwork

showing what bonds or notes they had purchased for her. Based on her conversations with

Brodacki after she sent the checks to Castle Hill, Advisory Client 2 assumed that Brodacki and

Castle Hill purchased notes or bonds with her $20,000 and those notes or bonds were in her

account managed by Brodacki and Castle Hill.

43. On information and belief, Brodacki and Castle Hill did not purchase notes or

bonds with the $20,000 they received from Advisory Client 2.

44. The Castle Hill bank statements indicate that, rather than making an investment

with the $20,000 that Advisory Client 2 entrusted to Brodacki and Castle Hill to invest for her

benefit, Brodacki and Castle Hill spent that $20,000 to benefit themselves.

45. The first $10,000 check from Advisory Client 2 was deposited into Castle Hill’s

bank account on June 9, 2023. At that time, Castle Hill’s account contained about $9,600. By

June 27, 2023, there was a negative balance of -$825 in Castle Hill’s account. Expenditures of

those funds included: $11,000 in transfers to Brodacki’s personal account, $1,600 in insurance

payments, a $3,000 check to Brodacki and various other purchases.

46. The second $10,000 check from Advisory Client 2 was deposited into Castle

Hill’s bank account on August 9, 2024. At that time, Castle Hill’s account contained about $100.

Over the next month, almost all of those funds were spent, leaving a balance in Castle Hill’s

account of approximately $900. Expenditures of those funds included: transfers to Brodacki’s

personal account that then resulted in $2,600 in cash withdrawals, payments on credit cards or

loans of about $2,800, Castle Hill office rent of about $900, dining and entertainment expenses

of over $400, travel expenses of about $250, and a payment on another advisory client’s life

insurance policy of over $2,100.

47. Advisory Client 2 never authorized Brodacki and Castle Hill to use her money for

their personal expenses or for Castle Hill’s office expenses. Advisory Client 2 did not authorize

Brodacki and Castle Hill to comingle her money with funds that did not belong to her. Advisory

Client 2 would not have sent her $20,000 to Brodacki and Castle Hill if she had known they

would use some or all of it for personal or office expenses.

Advisory Client 3

48. Advisory Client 3 is a phlebotomist, aged 56. Advisory Client 3 worked with

Brodacki as her investment adviser for about 24 years. Advisory Client 3 entered into an

Advisory Agreement with the Registered Adviser (doing business through Castle Hill). As part

of this Advisory Agreement, Advisory Client 3 established brokerage accounts at the Custodian

that were managed by Brodacki and Castle Hill.

49. In addition to working with Brodacki as her investment adviser, Advisory Client 3

considered Brodacki to be a friend.

50. In the spring of 2025, Advisory Client 3 and Brodacki began having discussions

about her making an investment into his business, Castle Hill. Advisory Client 3 wished to

invest in Castle Hill because she believed that Castle Hill and Brodacki were successful based on

his representations to her and the fact that she trusted him.

51. To make her investment into Castle Hill, Advisory Client 3 gave four checks,

each in the amount of $75,000 and made out to Castle Hill, to Brodacki. The four checks,

totaling $300,000, were all dated May 7, 2025, but were deposited by Castle Hill on May 8,

2025, May 12, 2025, May 23, 2025 and May 30, 2025. In return, Advisory Client 3 agreed with

Brodacki that she would be paid 8% interest on her investment in his business.

52. Advisory Client 3 intended that one of the four checks that she gave to Brodacki,

or $75,000, would not be part of her investment in Castle Hill, but rather a payment for past

advisory services he had provided to her when her parent died. Advisory Client 3 did not,

however, document her separate intention for one of the four checks, and does not know whether

Brodacki understood whether she was investing $300,000 or $225,000 in Castle Hill’s business.

53. Bank statements indicate that, rather than using Advisory Client 3’s $300,000 or

$225,000 as an investment in Castle Hill’s business, Brodacki and Castle Hill spent her money

for Brodacki’s personal benefit.

54. The $300,000 in checks from Advisory Client 3 were deposited into Castle Hill’s

bank account beginning on May 8, 2025. At that time, Castle Hill’s account contained about

$39,000. Other than about $120 in unrelated deposits, the $300,000 from Advisory Client 3 was

the only money deposited into Castle Hill’s bank account between May 2025 and the end of July

2025. Over the two months, almost all of those funds were spent, leaving a balance in Castle

Hill’s account as of July 31, 2025 of approximately $1,600. Expenditures of those funds

included: payments of tuition for Brodacki’s relatives of over $84,000, payments on credit cards

or loans of about $66,800, a payment to another advisory client of over $10,000, payments to

Brodacki’s in-laws of over $65,000, payments to Brodacki personally of over $20,000, dining

and entertainment expenses of over $9,000, travel expenses of over $14,900, and cash

withdrawals of over $14,000.

55. Advisory Client 3 never authorized Brodacki and Castle Hill to use her money for

their personal expenses. Specifically, Advisory Client 3 did not authorize Brodacki to use her

investment funds for tuition, for payments to relatives or other advisory clients, for payments to

himself personally, for travel, or for cash withdrawals. Advisory Client 3 would not have given

$300,000 to Brodacki and Castle Hill if she had known they would use some or all of it as

reflected in the bank records.

The Scope of Brodacki’s and Castle Hill’s Misconduct

56. Brodacki and Castle Hill misappropriated funds from at least 18 advisory clients,

who provided those funds to them for investment purposes. Certain details concerning each of

these instances of misappropriation are described in the chart below.

Advisory
Client

Age/ Occupation Investment
Amount/Date

Purported Investment Repayment/
Date

1 77, retired $50,000 - 7/18/22
$50,000 - 7/21/22

For investment in company New
England Note for client’s sister

2 73, retired $10,000 - 6/9/23
$10,000 - 8/9/24

For investment in non-bank notes or
non-bank bonds with an interest rate of
6% or 8%

3 56, phlebotomist $300,000 - 5/7/25 For investment in Castle Hill to be
repaid in 24 months with an 8% return

4 37, sports agency
recruiter

$50,000 - 9/2/25 For investment at Brodacki’s discretion
in a note or bond earning 8% interest

5 84, retired $30,000 - 5/28/24
$50,000 - 7/29/24

For unknown investment at Brodacki’s
discretion

$50,750 -
7/14/25

6 82, retired $30,000 - 5/25/22
$20,000 - 9/6/22

For unknown investment at Brodacki’s
discretion

7 85, retired $50,000 - 3/8/19 For unknown investment at Brodacki’s
discretion

8 75, retired $15,000 - 2/12/20 For unknown investment at Brodacki’s $0

$20,000 - 2/22/21
$20,000 - 12/17/21
$25,000 - 3/8/24

discretion

9 64 $10,000 - 12/15/20
$25,000 - 8/18/21
$10,000 - 12/2/21

For investment in stocks, including a
$10,000 private equity investment and
bonds at Brodacki’s discretion

$10,500 -
6/27/25

10 78, retired $6,000 - 8/16/18
$15,000 - 9/16/19
$150,000 - 6/28/23
$60,000 - 12/7/23
$20,000 - 3/14/24

For investment at Brodacki’s
discretion, including for bonds

$101,500 -
various dates
from 1/30/23
to 11/13/25

11 74, retired $64,000 - 10/1/18
$20,000 - 10/24/19
$6,500 - 10/29/19
$20,000 - 8/11/20
$20,000 - 10/27/22

For investment in CDs or a fund with
an interest rate higher than client’s
savings account

12 54 $303,585.68 -
1/27/23

To “overfund” client’s life insurance
policy to have funds available to be
invested at Brodacki’s discretion when
market was more favorable

13 53, police officer $25,000 - 5/8/24 For private equity investment in social
media company

14 64 $20,000 - 8/31/18
$50,000 - 5/17/19

For unknown investment at Brodacki’s
discretion

15 68, retired $50,000 - 6/5/18 For unknown investment at Brodacki’s
discretion

16 63, retired $25,000 - 4/15/24 For unknown investment at Brodacki’s
discretion

17 54, plumber $80,000 - 12/5/22
$25,000 - 9/20/23
$10,000 - 4/16/25
$80,000 - 4/25/25

For investment at Brodacki’s discretion
for retirement and for client’s grandson

18 74 $20,000 - 1/3/25 Investment in high-yield bank account
with 5% interest rate for client’s
grandchildren

Totals $1,845.085.68 $162,750

57. As the chart above demonstrates, over a nearly five-year period, Brodacki and

Castle Hill promised to invest over $1.845 million on behalf of at least 18 of their advisory

clients. Over this same period, Brodacki and Castle Hill returned only $162,750 to those

investors, and most of those repayments were made using other advisory clients’ funds that were

entrusted to Brodacki and Castle Hill to invest on their own behalf, which is behavior typical of a

Ponzi scheme.

58. Bank records demonstrate that Brodacki and Castle Hill used little to none of

these investment funds to make investments for their advisory clients. Rather, bank records

show that Brodacki and Castle Hill used these funds for Brodacki’s personal expenses including

numerous vacations, tuition, an exclusive club membership, fine dining, car-related expenses and

his mortgage. Bank records also show that some of the funds were used for Castle Hill’s

business expenses including office rent, technology expenditures and investment-related

subscriptions. Thus, the net losses by Brodacki’s and Castle Hill’s 18 advisory clients

approximate $1.68 million.

59. At the time Brodacki and Castle Hill misappropriated these advisory clients’

funds, Brodacki and Castle Hill intended to, knew they were, or were reckless with regard to

whether they were, breaching their fiduciary duties to their advisory clients. Brodacki and Castle

Hill knew that the funds entrusted to them by their advisory clients were for the purposes of

investment and could not be used for their personal expenses. With the exception of funds from

Advisory Client 3, Brodacki and Castle Hill also knew that they could not use their advisory

clients’ funds for their business expenses.

60. Even after Brodacki and Castle Hill were terminated by the Registered Adviser,

they misled certain of their advisory clients about why they had ceased doing business with the

Registered Adviser, asserting to at least one advisory client that they were no longer associated

with the Registered Adviser because that firm was trying to steal their clients. In September

2025, Brodacki and Castle Hill also accepted investment funds from at least one advisory client

even though they were unaffiliated with a registered investment adviser at that point in time.

FIRST CLAIM FOR RELIEF – FRAUD BY INVESTMENT ADVISERS

Brodacki and Castle Hill Violated Section 206(1) of the Advisers Act

61. The Commission repeats and incorporates by reference the allegations in

paragraphs 1 through 60 above as if set forth fully herein.

62. During the Relevant Period, Brodacki and Castle Hill were “investment advisers”

within the meaning of Section 202(a)(11) of the Advisers Act [15 U.S.C. § 80b-2(a)(11)].

Brodacki and Castle Hill each were in the business of providing investment advice concerning

securities for compensation.

63. Brodacki and Castle Hill, acting intentionally, knowingly, or recklessly, by use of

the mails or any means or instrumentality of interstate commerce, directly or indirectly, employed a

device, scheme, or artifice to defraud certain of their advisory clients. In so doing, Brodacki and

Castle Hill have breached their fiduciary duties.

64. As a result, Brodacki and Castle Hill have violated and, unless enjoined, Castle

Hill will continue to violate, Section 206(1) of the Advisers Act [15 U.S.C. § 80b-6(1)].

SECOND CLAIM FOR RELIEF - FRAUD BY INVESTMENT ADVISERS

Brodacki and Castle Hill Violated Section 206(2) of the Advisers Act

65. The Commission repeats and incorporates by reference the allegations in

paragraphs 1 through 60 above as if set forth fully herein.

66. During the Relevant Period, Brodacki and Castle Hill were “investment advisers”

within the meaning of Section 202(a)(11) of the Advisers Act [15 U.S.C. § 80b-2(a)(11)].

Brodacki and Castle Hill each were in the business of providing investment advice concerning

securities for compensation.

67. Brodacki and Castle Hill, with knowledge, recklessness, or negligence, and while

acting as investment advisers, by use of the mails or any means or instrumentality of interstate

commerce, directly or indirectly engaged in transactions, practices, or a course of business which

operated as a fraud or deceit upon certain of their advisory clients. By doing so, Brodacki and

Castle Hill breached their fiduciary duties.

68. As a result, Brodacki and Castle Hill have violated and, unless enjoined, Castle

Hill 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 requests that this Court:

A. Permanently restrain Castle Hill, its 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 Sections 206(1)

and 206(2) of the Advisers Act by committing or engaging in specified actions or activities

relevant to such violations.

B. Order the Estate and Castle Hill to disgorge, with prejudgment interest, their ill-

gotten gains obtained by reason of the unlawful conduct alleged in this Complaint, on a joint and

several basis, pursuant to Section 21(d)(5) and (7) of the Securities Exchange Act of 1934 [15

U.S.C. §78u(d)(5), (7)];

C. Order Castle Hill to pay an appropriate civil monetary penalty pursuant to Section

209(e) of the Advisors Act [15 U.S.C. §80b-9(e)];

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

orders and decrees that may be entered; and

E. 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: April 2, 2026

Respectfully submitted,

/s/ Kathleen Burdette Shields
Kathleen Burdette Shields (BBO #637438)
Louis Randazzo (New York Bar #2416485)

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) 573-8958 (Randazzo direct)
(617) 573-8929 (Mitza direct)

(617) 573-4590 (fax)
[email protected], [email protected],
[email protected]

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

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