For nearly a quarter century, John R. Brodacki III of Longmeadow, Massachusetts worked in financial advisory services, building a client base of approximately 110 people who trusted him with their retirement savings, inheritance funds, and money set aside for family members they wanted to protect. Between June 2018 and September 2025, he and his company Castle Hill Financial Group, LLC ran a parallel operation alongside the legitimate advisory business: soliciting at least 18 of those clients, many of them elderly, retired, or seriously ill, to send funds directly to Castle Hill for investment outside their normal custodian accounts, then spending that money on his personal and family expenses. The scheme had the hallmarks of a Ponzi scheme. Brodacki died on March 23, 2026. The SEC filed its complaint against his estate and Castle Hill ten days later.
How Brodacki Used Fabricated Investments to Keep Clients from Asking Questions
The mechanics were consistent across all 18 clients. Brodacki told each one that the funds would be invested in specific instruments: high-yield bank accounts, certificates of deposit, bonds, notes, private company securities, or accounts to benefit a client’s relatives. He instructed them to send checks or wire transfers payable directly to Castle Hill, bypassing the custodian brokerage accounts through which his legitimate advisory business operated. The client advisory agreements he had signed explicitly stated that “at no time will the Advisor accept, maintain possession or have custodial responsibility for the Client’s funds or securities.” He directed clients to violate those agreements while collecting his quarterly fees as if everything was normal.
Most of the 18 clients never received documentation showing what had been purchased with their funds. They trusted him. Many had worked with him for years, some for decades. One 56-year-old client had been with Brodacki as her investment adviser for approximately 24 years and considered him a friend. When the 77-year-old retired building contractor who wanted to leave $100,000 to his sister asked where the account had been established, Brodacki sent him fabricated monthly account statements showing an investment called “New England Note”, valued at $100,000 in February 2023, growing to $108,000 by September 2023, $124,000 by December 2024, and $127,000 by July 2025. The SEC’s complaint states that, on information and belief, no company called “New England Note” exists.
The Bank Records That Show What Actually Happened to Client Money
The complaint’s account of where the money went is drawn directly from Castle Hill’s bank records, and the pattern is the same across each client described. When the 77-year-old deposited $100,000, Castle Hill’s account held about $43,000. Over the following month, all of it was spent: more than $44,000 transferred to Brodacki’s personal account or withdrawn as cash, over $24,000 to a home improvement contractor, over $32,000 for office rent, $14,000 on credit card and loan payments, $8,000 on dining and entertainment, and $4,000 on travel. The balance left after one month: $438.
When the 73-year-old retired engineer who was terminally ill sent her first $10,000 check for what she believed were bonds or notes paying 6 to 8 percent interest, Castle Hill’s account held $9,600. Within weeks, the account had a negative balance. When she sent her second $10,000 check a year later, Castle Hill’s account held $100. Within a month, almost all of it was gone: to Brodacki’s personal account, to credit card payments, to another advisory client’s life insurance premium, to office rent. She never authorized any of it. She would not have sent the money, the SEC states, had she known.
The most significant single amount came from the 56-year-old phlebotomist who sent $300,000 in four checks in May 2025, believing she was investing in Castle Hill’s business at 8 percent interest. Castle Hill’s records show that over the following two months, nearly all of it was spent: over $84,000 in tuition for Brodacki’s relatives, over $65,000 to Brodacki’s in-laws, $66,800 in credit card and loan payments, $20,000 to Brodacki personally, $14,900 in travel, $14,000 in cash withdrawals, and $9,000 on dining and entertainment. The account balance at the end of July 2025: approximately $1,600.
Bay Colony Advisory Group Fired Brodacki in July 2025 but the Scheme Continued
For most of the scheme’s duration, Brodacki operated as an investment adviser representative of Bay Colony Advisory Group, a registered investment advisory firm. The compliance guidelines Bay Colony had established for its representatives were explicit: client checks must be made payable to the custodian, advisers cannot accept checks made out to themselves or their business, and advisory services cannot be paid directly to the adviser or their company. Brodacki violated every one of those rules across seven years without detection.
Bay Colony terminated Brodacki on July 11, 2025 after its internal investigation concluded he had improperly received client funds directly into a Castle Hill account, specifically, accepting what appeared to be a loan from a client without disclosing it to the firm. The termination was reported to FINRA with the notation that Brodacki had been dismissed for “violation of firm policies and procedures and industry regulations and conduct.”
After the termination, Brodacki and Castle Hill continued soliciting and accepting client funds. Castle Hill’s website continued advertising investment advisory services. According to the SEC’s complaint, at least one client was told that Brodacki had left Bay Colony because the firm was “trying to steal their clients.” The scheme continued accepting new client funds through at least September 2025. Castle Hill was involuntarily dissolved by the Commonwealth of Massachusetts on December 31, 2025. Brodacki died on March 23, 2026.
The Scope of the Losses and What the SEC Filed Against His Estate
Across the 18 clients, Brodacki and Castle Hill collected approximately $1.845 million over the seven-year period. Only $162,750 was returned, and most of those repayments were funded by other clients’ investment deposits, the defining characteristic of a Ponzi scheme. After deducting the repayments, the SEC estimates net client losses at approximately $1.68 million. The clients ranged in age from 37 to 85. Many were retired. One was terminally ill. The oldest, aged 85, had sent $50,000 in 2019 and received nothing back.
The SEC filed its complaint on April 2, 2026 in the District of Massachusetts against the personal representative of Brodacki’s estate and Castle Hill Financial Group, charging both with violating Sections 206(1) and 206(2) of the Investment Advisers Act of 1940. The SEC’s litigation is being handled by the Boston Regional Office. The SEC seeks disgorgement with prejudgment interest from both the estate and Castle Hill, a civil money penalty against Castle Hill, and a permanent injunction against Castle Hill from engaging in further advisory fraud.
Conclusion
John Brodacki spent seven years telling clients their money was being invested while spending it on vacations, tuition, family payments, club memberships, and home improvements. The clients who trusted him most, the ones who had known him for decades, the ones who were elderly and retired and ill, were the ones who sent the most money and received the least back. He died before the SEC could bring charges against him personally. The case now proceeds against his estate and against Castle Hill, a company the Commonwealth of Massachusetts had already dissolved before he died. The 18 clients who gave Brodacki their savings, their inheritance, and money they had set aside for their families are owed approximately $1.68 million that is unlikely to be fully recovered.
