Brook Church-Koegel, 49, of Marina Del Rey, California, has been suspended for 12 months from association with any broker, dealer, investment adviser, or related securities industry entity by the Securities and Exchange Commission, following a consent judgment entered against him in April 2024 for his role as one of the top revenue-producing internal sales agents at Woodbridge Group of Companies LLC, which operated one of the largest real estate Ponzi schemes in American history. From at least June 2014 through December 2017, Church-Koegel sold unregistered Woodbridge securities to hundreds of investors, many of them elderly retirees investing retirement savings, and served as a team leader coordinating the sales efforts of internal and external agents across the country. He and two fellow internal salespersons, David Goldman and Nicole Walker, together sold approximately $444 million in Woodbridge securities in unregistered transactions. Church-Koegel received commissions both in his own name and through his wholly-owned alter ego company Whyte and Brown Inc., which has since been administratively dissolved. He has never been registered as a broker-dealer. Woodbridge founder Robert Shapiro was sentenced to 25 years in federal prison. The SEC’s 12-month suspension order was issued May 13, 2026.
Woodbridge Raised $1.22B from 8,400 Investors by Pretending to Make Real Estate Loans That Did Not Exist
Woodbridge presented itself as a high-end real estate lending company that issued short-term, high-interest commercial loans to property owners and passed the interest income on to investors. It promised returns of 5 to 10 percent annually and boasted a 90% renewal rate. The underlying business was a fiction. The vast majority of the supposed borrowers were companies owned by Shapiro himself, which had no income and never made interest payments. Woodbridge could only pay investors by continuously raising new investor money, the defining structure of a Ponzi scheme. The scheme ran from July 2012 through December 4, 2017, when Shapiro filed for bankruptcy.
Church-Koegel and his fellow salespeople pitched Woodbridge’s securities to the general public through email, telephone, in-person meetings, and marketing materials that described the investments as “safer” and “conservative.” Many of the investors targeted were elderly retirees who used IRA funds to invest. Neither Woodbridge nor any of the internal sales agents took steps to verify whether investors were accredited. The two primary products sold were 12 to 18 month term promissory notes that Woodbridge called First Position Commercial Mortgages, and private placement fund offerings with five-year terms. Neither product was registered with the SEC, and no exemption from registration applied.
Church-Koegel Became a Team Leader Coordinating Agents Across the Country and in Multiple Districts
Church-Koegel’s role expanded beyond direct sales. He and David Goldman became team leaders within Woodbridge’s internal sales organization, responsible for training and coordinating the efforts of other internal sales agents and regularly joining calls with external agents and their investor prospects to answer questions about Woodbridge’s products. According to the SEC’s original complaint filed in March 2020, Church-Koegel sold to approximately 1,600 investors directly or assisted others who sold to them. In one federal district alone, he coordinated with at least four external agents who sold at least $10.5 million of Woodbridge securities and directly sold at least $1.8 million to eight investors.
Church-Koegel received commissions both personally and through Whyte and Brown Inc., a company he wholly owned that has since been administratively dissolved. Goldman received $659,353.91 in commissions plus a salary of over $192,000 during the applicable period alone. Church-Koegel’s total compensation was not disclosed in the SEC order, but Woodbridge paid at least $64.5 million in total commissions to its sales agent network over the life of the scheme.
Shapiro Got 25 Years, and the SEC Has Pursued the Sales Network Through Multiple Enforcement Actions
Robert Shapiro pleaded guilty in August 2019 to conspiracy to commit mail and wire fraud and tax evasion, admitting he had misappropriated between $25 million and $95 million of investor money for personal use including a Los Angeles estate, chartered planes, jewellery, artwork by Picasso and Renoir, and vintage wines. He was sentenced to 25 years in federal prison in October 2019. Former Woodbridge directors of investments Dayne Roseman and Ivan Acevedo were separately charged with conspiracy and fraud.
The SEC charged Church-Koegel, Goldman, and Walker in March 2020. Church-Koegel’s civil case, filed in the Central District of California, concluded with a consent judgment on April 11, 2024 that permanently enjoined him from future violations of the registration provisions of the Securities Act and Exchange Act. The SEC then instituted administrative proceedings in June 2024 to impose an industry bar, which Church-Koegel settled with the 12-month suspension order issued May 13, 2026. The Goldman and Walker administrative proceedings are at various stages of the enforcement pipeline.
Conclusion
Brook Church-Koegel spent more than three years as one of the top salespeople at a $1.22 billion Ponzi scheme that targeted elderly retirees with retirement savings and IRA accounts, pitching products that were described as safer than they were and selling securities that were never registered. The civil judgment came in 2024. The 12-month SEC suspension comes in 2026, nearly nine years after Woodbridge collapsed. It is a lighter sanction than a permanent bar, reflecting the consent settlement rather than a litigated outcome. The investors Church-Koegel helped recruit into a fraud that has already sent its founder to prison for 25 years are likely to recover only a fraction of what they invested.
