SEC Files Fraud Charges Against Estate of Deceased Massachusetts Adviser

The U.S. Securities and Exchange Commission filed a formal complaint in the U.S. District Court for the District of Massachusetts against the estate of John R. Brodacki III and his firm, Castle Hill Financial Group LLC. The lawsuit alleges a years-long fraudulent scheme that misappropriated approximately $1.68 million from at least 18 advisory clients, many of them elderly, retired, or terminally ill.
According to the SEC’s complaint, Brodacki and Castle Hill operated as investment advisers and owed a fiduciary duty to their clients. Between June 2018 and September 2025, they allegedly breached those duties by inducing clients to transfer funds directly to Castle Hill under the guise of making specialized investments.
Brodacki purportedly told clients their money would be used for high-yield bank accounts, stocks, bonds, or private company securities. In reality, the SEC alleges the funds were used for: personal expenses, such as lavish meals, exclusive social club memberships, travel, and tuition for Brodacki’s family members; Ponzi-like payments to other advisory clients to maintain the appearance of legitimate investment returns; and paying Castle Hill’s office rent and technology subscriptions.
To further the deception, Brodacki allegedly provided at least one client with fabricated account statements that showed the supposed growth of non-existent investments.
The SEC said Brodacki had previously been associated with an SEC-registered investment advisory firm that terminated his employment in July 2025 following an internal investigation into his improper receipt of client funds.
Despite this termination, Brodacki and Castle Hill allegedly continued to solicit and accept client funds through December 2025. During this period, Brodacki allegedly misled clients about his status, claiming his former firm was simply “trying to steal their clients.”
The complaint outlines specific instances of misappropriation:
Advisory Client 1: A 77-year-old retired contractor who entrusted $100,000 to Brodacki to create an account for his sister. Within a month, the balance of the account where these funds were deposited dropped to $438 after being spent on Brodacki’s personal home improvements, rent, and travel.
Advisory Client 2: A 73-year-old terminally ill retired engineer who provided $20,000 for safe bank certificates of deposit. These funds were allegedly used for Brodacki’s personal cash withdrawals and insurance payments.
Advisory Client 3: A 56-year-old phlebotomist who invested $300,000 in Castle Hill’s business. Instead of being used for business growth, over $84,000 was allegedly used for tuition for Brodacki’s relatives and over $65,000 was paid to his in-laws.
Brodacki died in March, shortly before the charges were finalized. As a result, the SEC has named the personal representative of the estate as a defendant.
The defendants are charged with violating Sections 206(1) and 206(2) of the Investment Advisers Act of 1940. The SEC is seeking disgorgement, with the return of all “ill-gotten gains” plus interest from both the estate and Castle Hill. The commission is also seeking monetary/civil penalties against Castle Hill, and a court order to permanently bar Castle Hill from further violations of federal securities laws.


