Getting into compliance for the money rarely pays off. Just ask David Goulding.
Goulding was the chief compliance officer for now-defunct investment advisory firm The Nutmeg Group. In November 2019, the Securities and Exchange Commission won a trial against Nutmeg regarding fraud charges the SEC brought in March 2009 for misappropriating client assets and misrepresenting the value of 15 unregistered investment pools. Magistrate Judge Jeffrey T. Gilbert of the U.S. District Court for the Northern District of Illinois ruled Randall Goulding, owner and managing member of the firm, “used Nutmeg as his personal piggybank” in addition to commingling investor funds and working within poor internal control systems. Goulding was forced to pay north of $1.8 million in penalties.
