Lawrence Billimek was an equity trader at Nuveen, the asset management arm of TIAA, which manages roughly $1.3 trillion. His job was to route the orders that portfolio managers decided on, which meant he knew what the firm was about to buy before it bought it, and knew that orders that size move a share price in a predictable direction. Alan Williams, a retired financial industry veteran in West Linn, Oregon who had held Series 1, 7 and 55 licences since 1971, traded the other side of that knowledge. Over more than a thousand trades between September 2016 and August 2022, Williams bought the same stocks moments before Nuveen’s orders hit, sold as the price moved, and sent Billimek more than $10 million of the proceeds. On September 17, 2026, the Securities and Exchange Commission filed proposed final judgments closing its case.
The judgments, subject to court approval, permanently enjoin both men from violating Section 17(a) of the Securities Act and Section 10(b) of the Exchange Act and Rule 10b-5, and enjoin Billimek from violating Section 17(j) of the Investment Company Act and Rules 17j-1(b)(1) and (3). They order disgorgement of $12,684,000 from Billimek and $34,627,659 plus $12,027,557.75 in prejudgment interest from Williams, more than $59 million in total, all deemed satisfied by the forfeiture already ordered in the criminal case.
Twenty-Two Searches for Boost Mobile
The men did not use their own phones for the tips. From December 2020 to April 2022, Williams communicated with a Boost Mobile prepaid handset at or shortly before the moments trades were placed in his accounts. Between November 2021 and April 2022 that phone sent 1,465 text messages, and 1,460 of them, 99.66 percent, went to Williams.
The SEC’s complaint sets out how it was tied back. Between January 2018 and May 2021, a Google account associated with Billimek searched for Boost Mobile 22 times, and close to some of those searches it also searched the zip code for Lenexa, Kansas, the billing address of the prepaid phone. That phone’s account was opened on August 30, 2016, days before the scheme began. When it went quiet on April 1, 2022, a second prepaid phone took over three days later, and from October to November 2022 that second handset was repeatedly in roughly the same location as a phone registered to Billimek.
Three Round Trips in One Day
The trading pattern is visible in a single session the complaint reconstructs minute by minute. On July 8, 2022, in a California beverage company’s stock, Williams exchanged texts with the burner at 9:58am, bought 69,000 shares between 10:00 and 10:32, texted again, watched Nuveen’s funds buy at least 64,343 shares from 10:35, and sold his entire position at 10:43.
He did it twice more the same day. At 12:52pm he texted, bought 57,000 shares, Nuveen bought 70,838, and he sold at 1:32pm. At 2:14pm he texted, bought 40,000 shares, Nuveen bought 78,402, and he sold at 3:40pm. One stock, one day, three round trips, roughly $169,900. Among the companies named when Billimek pleaded guilty were Lululemon Athletica and Ulta Beauty.
The Tool That Caught Them Is Now Under Review
Nobody at Nuveen spotted this. What did was the Consolidated Audit Trail, the database the SEC spent more than a decade building, which records as many as 500 billion trade events a day across United States markets. Staff in the Market Abuse Unit used it to find Williams’s trading and match it against Nuveen’s order flow. When the case was announced in December 2022, Market Abuse Unit chief Joseph Sansone said staff would use the data analytics tools at their disposal to find and charge illegal trading.
This was among the first criminal prosecutions built on CAT data, and the same database later featured in the case against Justin Chen of EdgarAgents, whose trading across a dozen unrelated issuers was invisible to any single company but obvious across every market at once. There is an irony in the timing. By the time Williams was sentenced in April 2025, the CAT was under political pressure, with the administration weighing whether to rein it in. Billimek’s own lawyer, Marc Mukasey, argued at sentencing that publicity about the tool had itself deterred others, so a long sentence was unnecessary.
Gifts, and a Man Living Paycheck to Paycheck
The money moved by cheque and wire, and when banks asked, the two men described the transfers as gifts. Prosecutors put the total sent to Billimek at more than $10 million. The complaint identified at least $540,000 reaching a bank account in his name.
His defence was that this began in hardship rather than greed. Prosecutors cited a 2016 email in which Billimek wrote that he was struggling and living paycheck to paycheck, and his lawyers pointed to unemployment after the 2008 crisis. Against that, prosecutors set the property portfolio the scheme paid for, in New Orleans, Austin, San Antonio, Hawaii, Oregon and Idaho, all of which he agreed to surrender along with more than $4 million in cash. At his plea he told the court he knew what he was doing was wrong and asked for mercy.
The Insider Owes a Quarter of What the Trader Owes
The split in the judgments is worth reading closely. Williams, who placed the trades and held the accounts, owes $34.6 million plus $12 million in interest. Billimek, who breached the duty that made any of it possible, owes $12.7 million. The disgorgement follows where the money stayed, not where the wrongdoing started.
The prison terms ran the other way. Billimek pleaded guilty in November 2023 to one count of securities fraud and was sentenced in May 2024 by U.S. District Judge Paul G. Gardephe to 70 months, three years of supervised release and $12.24 million in forfeiture. He was also held jointly liable for more than $38 million in restitution to TIAA-CREF, the judge rejecting part of the firm’s claim. Williams, who pleaded guilty two months earlier to four counts and cooperated against Billimek, was sentenced in April 2025, at 79, to one year.
Conclusion
For six years Lawrence Billimek told Alan Williams what Nuveen was about to buy, minutes before it bought it, using prepaid phones bought from a Kansas billing address he had looked up on Google. Williams stepped in front of more than a thousand orders belonging to the pension savers and fund investors Nuveen manages money for, and sent back more than $10 million in payments the pair called gifts. Nuveen never noticed. A federal database that logs half a trillion trade events a day did. Billimek got 70 months, Williams got a year, and the final judgments filed this month put the number at more than $59 million.
