SEC Wins Settlements From Networks That Sold Notes in $50M Florida Real Estate Ponzi

The U.S. Securities and Exchange Commission filed settled enforcement actions on June 23 against two unregistered sales agent networks that together raised approximately $50 million for Wells Real Estate Investment, LLC, an alleged $56 million Ponzi scheme based in West Palm Beach, Fla., that targeted retail investors including seniors and retirees who invested retirement savings.
The two actions – filed in federal courts in Texas and Florida – target Sanders Family Office, LLC, a California-registered entity operating out of Boerne, Texas, and its principal Margaret Sanders, and Francisco J. Herrera, a San Jose, Calif., life insurance agent who sold the notes through a Spanish-language radio program and social media. Neither Sanders, her firm, nor Herrera held securities licenses or were registered broker-dealers at any point during their sales activity.
Sanders Family Office and Sanders, without admitting the SEC’s allegations, agreed to a consent judgment that would require them to pay disgorgement of $2,977,099.53 plus prejudgment interest of $506,228.74 – equal to the commissions they received from Wells – and impose a $100,000 civil penalty against Sanders personally, subject to court approval. The SEC’s complaint alleges that from August 2020 to March 2023, Sanders and her agents raised approximately $40 million from about 600 investors, making them the largest single source of investor funds in the Wells scheme. Sanders and her firm trained a multi-state network of sales agents, hosted regular Zoom presentations for prospective investors, facilitated the rollover of retirement account funds, including 401(k) accounts, into self-directed IRAs to purchase the notes, and instructed sales agents not to contact Wells directly but to route all investor questions through them.
Herrera consented to a bifurcated judgment under which injunctive relief is certain but the amounts of disgorgement and civil penalties will be determined by the court at a later date. The SEC alleges that Herrera raised approximately $10 million from about 190 investors through his sales team in Arizona, Colorado and New Mexico, promoting the notes on social media platforms including YouTube, LinkedIn, and Instagram, and on his Spanish-language radio program “Duplica Tu Dinero” (“Double Your Money”). Approximately half of the investors Herrera sold notes to originated through that radio show. He received at least $488,244 in commissions.
Wells marketed its promissory notes – carrying interest rates of 10% to 12% annually on 18- and 28-month terms, or a lump-sum 99% interest payment at the end of three years – as collateralized by South Florida real estate and backed by a purported $450 million real estate portfolio.
In reality, the SEC alleged in its original August 2024 emergency complaint, Wells – run by founder and chief executive officer Janalie Bingham and her husband Jean Joseph, an undisclosed convicted felon – used approximately $11 million of the $56 million raised to purchase real properties that were heavily mortgaged and generated insufficient income to service investors. Bingham and Joseph allegedly diverted approximately $28 million to brokerage accounts and lost roughly $11.9 million on speculative futures and options trading, used approximately $10 million in Ponzi-like fashion to pay earlier investors, paid approximately $6.9 million in undisclosed commissions to sales agents, and misappropriated approximately $1.8 million for personal expenses. Joseph, who had previously pleaded guilty to wire fraud in 2019 in an unrelated scheme and served 15 months in federal prison, was a control person of Wells whose criminal history was concealed from investors. On June 11, 2026, Joseph was sentenced to 240 months, or 20 years, in federal prison following a guilty plea to conspiracy to commit money laundering. Bingham pleaded guilty to conspiracy to commit wire fraud in February 2026.
A receiver appointed by the court is working to recover funds for the approximately 660 investors who purchased the notes.
The Wells enforcement action echoes patterns the SEC and the Financial Industry Regulatory Authority have documented in prior retail fraud cases: unlicensed, commission-driven sales agent networks operating outside the registered broker-dealer framework, targeting retail and retirement investors with above-market yield promises collateralized by assets that did not exist at the represented values. The distribution infrastructure that Sanders and Herrera built – multi-state agent networks, social media outreach, Spanish-language radio programming, and systematic retirement account rollovers – illustrates the persistent vulnerability in the self-directed IRA and alternative investment markets that regulators have repeatedly flagged.


