On Thursday, February 2, 2017, the SEC filed a civil
complaint in Connecticut federal court against Mark J. Varacchi and Sentinel
Growth Fund Management, alleging that the defendants misappropriated at least
$3.95 million of investor assets at two private funds the defendants
advised/managed. https://www.sec.gov/litigation/complaints/2017/comp-pr2017-40.pdf. According to the complaint, the defendants
used investor money for personal and business expenses, and to pay prior
investors, which would be a Ponzi scheme.
This violated defendants’ fiduciary duty to their clients.
Sentinel’s purported business model was to provide a
platform for investors to “invest with up-and-coming hedge fund managers.” The defendants claimed to have a “master fund
that included multiple series managed by the [designated hedge fund
managers]. Investor funds either were
never invested in the designated hedge funds, or redeemed without authorization.
The SEC seeks disgorgement and penalties against Varacchi
and Sentinel, and also named two hedge funds in an attempt to recover investor
assets allegedly in those funds’ possession.
Neither Sentinel Growth Fund Management, nor Mark Varacchi
are registered representatives in the Central Registration Depository, which is
the database FINRA maintains of all individuals who are financial advisors
(either broker-dealer agents or investment adviser representatives). As a result, neither appear when search on
FINRA’s broker-check website: https://brokercheck.finra.org/search/genericsearch/grid. Nor do either appear on SEC’s Investment
Adviser Public Disclosure website: https://www.adviserinfo.sec.gov/.
It is easy to post a website claiming your firm as the “Best
Emerging Manager Managed Account Platform 2016.” http://www.wealthandfinance-intl.com/sentinel-growth-fund-management. It is much more difficult to take the FINRA
Series tests required in order to become a registered financial advisor. While investing with any given registered
persons is no guarantee as to honesty or market returns, placing investor funds
with unregistered persons is the single easiest way to lose money in
investing. This is true whether you are
investing a modest nest egg, or chasing yield in a supposedly curated hedge fund
strategy.
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