Michael D. Williams of Port St. Lucie, Florida, worked as an administrative assistant and pension plan administrator at a company that administers police and firefighter pension plans in West Palm Beach. That job is why serving and retired law enforcement officers believed him when he told them he could trade their savings. Through CMI Capital, LLC, which did business as Check Mate Investments, he raised approximately $860,000 from at least 18 investors between October 2023 and August 2024, selling interests in two pooled funds he called CMI Fund 1 and CMI Fund 2. Neither fund was ever incorporated. He never opened a brokerage account for either. He has never been registered with the Securities and Exchange Commission and has never held a securities licence. On September 23, 2026, the SEC charged him and CMI in the Southern District of Florida.
The complaint charges both with violating Sections 5(a), 5(c) and 17(a) of the Securities Act, Section 10(b) of the Exchange Act and Rule 10b-5, and Sections 206(1), 206(2) and 206(4) of the Investment Advisers Act and Rule 206(4)-8. Williams and CMI have agreed to a bifurcated settlement, subject to court approval, that would permanently enjoin them and bar Williams from participating in any securities offering except for certain trades in his own accounts. Monetary relief is left for the court to decide later. The pension administration company is not named, did not take part in the scheme, and is not accused of anything.
The Profits Were From a Practice Account
The central deception was visual. Williams sent investors screenshots showing large trading gains, posting them to a Facebook group chat set up for CMI investors. The trades in those screenshots were placed on a practice trading platform, the kind brokerages provide so that people can learn without risking money. He cropped the images so the part identifying them as simulated did not appear.
Stephanie Moot, director of the SEC’s Miami office, put it plainly in the announcement, saying one of the tactics used to trick investors was sending them cropped screenshots of graphics showing exorbitant trading profits. Alongside the images came investor letters, monthly reports and social media messages containing what the SEC calls fabricated returns, fictitious portfolio values and false claims of past performance. Investors were told at one point that a fund held a portfolio worth more than $5 million.
187 Percent, and a 65 Percent Loss
The written pitch made specific claims. In letters sent in January, April and May 2024, the defendants told investors that over the previous five years the CMI options strategy had delivered year over year performance of 187 percent, with 2023 returning 331 percent. They wrote that the funds would be actively managed daily, that trading could be maximised for profitability with little to no risk, and that the funds could sit in full cash at the end of every day.
There was no CMI strategy. The track record described belonged to Williams’s own personal trading in options contracts, and according to the complaint that record was marked by years-long losing streaks, including a 65 percent loss in 2023, the same year he told investors the strategy returned 331 percent. Investor money went into his personal bank account and then into his personal brokerage accounts. His trading on behalf of the purported funds produced aggregate losses of at least $428,000.
The Pension Office and the Police Benevolent Association
What made the pitch work was where it came from. Williams solicited police pensioners and serving officers while working at the pension administration company, and used his work email address to do it. On at least one occasion he met investors at the company’s satellite office inside the Police Benevolent Association in West Palm Beach. His employer knew none of this.
He also ran a Facebook group that charged a $100 fee for investment advice, including to people he had no prior relationship with, and asked existing investors to bring in friends and family. No reasonable steps were taken to check whether any of them were accredited, and several were not, with no substantial investing experience. The monthly reports he sent contained a portfolio value and a profit figure and nothing else. No financial statements for either fund were ever provided, which would have been difficult, since neither fund existed as a legal entity.
The structure echoes the case against Ernest Ossei Boateng, who raised $16 million from members of his own church community while holding no licence of any kind. In both, the seller’s standing inside a trusted group did the work that a prospectus and a registration would otherwise have to do.
A Sports Car, Jewellery and Medical Spa Treatments
While presenting himself as an accomplished manager, and, in the SEC’s words, bragging about buying luxury vehicles and high-end watches, Williams diverted at least 45 percent of everything raised. The precise figure in the complaint is $383,675.37. It went on credit card balances, his mortgage, car expenses, cash withdrawals, a high-end sports car and luxury car rentals, jewellery, vacations, restaurants and medical spa treatments.
The people funding that were, in several cases, police officers investing money meant for their retirement, who had found Williams through the office that administers their pension.
His Family Paid the Money Back
It collapsed in August 2024, when investors worked out that the returns they were being shown came from a simulated account rather than a real one. Williams began making repayments to quiet the concerns, and has returned more than $375,000.
The complaint records where that money came from. The repayments were made largely using funds provided by Williams’s family for the purpose of repaying investors, and they were made before the Commission opened its investigation. So the restitution such as it is did not come from trading profits, because there were none, and did not come from the $383,675.37 he had already spent. It came from his relatives.
Conclusion
Michael D. Williams had no licence, no registration, no brokerage account for his funds, and no funds, because he never incorporated either one. What he had was a job at the company that administers police and firefighter pensions, an email address to match, and access to an office inside the Police Benevolent Association. He told officers his options strategy had returned 187 percent a year and 331 percent in 2023, a year his own trading lost 65 percent. He proved it with screenshots from a practice account, cropped so nobody could see the word demo. He took $860,000, spent $383,675.37 of it on a sports car, jewellery and spa treatments, lost $428,000 more in the market, and when it unravelled his family paid the investors back.
