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The SEC's complaint, filed on January 24, 2023, alleged that Liddle, while acting as an investment adviser, fabricated documents and made misrepresentations to clients, many of whom were seniors. Liddle misrepresented that these clients' portfolios had become too risky and needed to be replaced with less risky securities. These "less risky" securities were often rated as high risk and were also unavailable. Liddle had advisory clients send money directly to his investment advisory company, where Liddle misappropriated client funds and never invested the money on his clients' behalf. Liddle also fabricated statements and made purported investment payments to advisory clients that were, in fact, coming from defrauded client funds.

The final judgment, which was entered by consent, enjoins Liddle from future violations of the antifraud provisions of Section 17(a) of the Securities Act of 1933, Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder, and Sections 206(1) and (2) of the Investment Advisers Act of 1940. The judgment also bars Liddle from acting as an officer or director of any issuer that has a class of securities registered pursuant to Section 12 of the Exchange Act. In addition, the judgment orders Liddle to pay disgorgement in the amount of $1,662,041.80, but deems this obligation fully satisfied by the entry of a restitution order in a parallel criminal case filed in the U.S. District Court for the Western District of Wisconsin, in which Liddle pleaded guilty to one count of wire fraud and one count of money laundering and was sentenced to serve 97 months in prison.

The SEC's litigation in this matter is now concluded.

The SEC's investigation was conducted by Matthew T. Wissa and Scott Hlavacek and supervised by Amy S. Cotter of the Chicago Regional Office. The litigation was handled by Mr. Wissa and Ms. Cotter.

The SEC appreciates the assistance of the Wisconsin Department of Financial Institutions - Division of Securities, the Wisconsin Office of the Commissioner of Insurance, and the Financial Industry Regulatory Authority.