SEC v. Bennett Group Financial Services, LLC and Dawn J. Bennett (2015)
Judgment entered
Checked against the primary document on October 4, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, with sampled and disputed records read a second time. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.
The SEC's September 2015 administrative case against adviser Bennett Group Financial Services and Dawn Bennett ended in a Commission opinion and order of 30 March 2017. The Commission found that they willfully violated antifraud rules, barred Bennett from the industry, and ordered $556,102 in disgorgement plus interest and penalties of $2.9 million on the firm and $600,000 on Bennett.
The record
| Agency | SEC |
|---|---|
| Release number | 3-16801 |
| Date filed | 2015-09-09 |
| Date resolved | 2017-03-30 |
| Status | judgment |
| Criminal parallel | No |
| Bars imposed | industry-wide association bar, penny stock bar |
| Defendants | Bennett Group Financial Services, LLC ; Dawn J. Bennett |
| Cited as charged or alleged | Advisers Act s.206 ; Exchange Act s.10(b) and Rule 10b-5 ; Securities Act s.17(a) |
| Techniques |
What was ordered
- Civil penalty
- $3.5m
- Disgorgement
- $556k
- Prejudgment interest
- —
- Total relief
- $4.1m
- Alleged gain
- —
What is alleged to have happened
The Securities and Exchange Commission instituted this administrative and cease-and-desist proceeding on September 9, 2015 as file 3-16801. The respondents are Bennett Group Financial Services, LLC and Dawn J. Bennett (1 individual, 1 entity). The order sets out the Division of Enforcement's allegations and sets a hearing; it is not a settlement and contains no findings.
The Division alleges that from at least 2009 through February 2011 the firm and Bennett overstated the assets they managed by at least $1.5 billion, claimed the amount to a financial advisor ranking service and on Bennett's Washington-area radio program, and described a model portfolio's returns as if they were client returns. It further alleges they lied to SEC staff during the investigation by claiming advice to three corporate clients that was never given, and that the firm lacked adequate policies for calculating assets and returns.
The order's one use of "churning" refers to two 2014 arbitration awards against Bennett and is background, not a charge, so this library applies no technique tag.
An administrative law judge found that the firm and Bennett overstated assets under management and investment returns, and respondents appealed to the Commission, arguing only that the judge's appointment was unconstitutional. In its opinion of 30 March 2017 the Commission rejected that argument and imposed sanctions: it barred Bennett from association with a broker, dealer, investment adviser and similar firms and from a penny stock offering, prohibited her from serving certain investment company roles, ordered both respondents to cease and desist, ordered them to disgorge $556,102 jointly and severally with prejudgment interest running from March 2011, and imposed civil penalties of $2.9 million on the firm and $600,000 on Bennett. The respondents had the right to seek review in a court of appeals; this page does not say whether they did, and the interest amount is not stated as a fixed figure.
For the regulator's own account of the facts, read the primary documents linked above. This page summarises the structured record and does not reproduce them.
Timeline
- 2015-09-09 Administrative proceeding instituted (cease-and-desist)
- 2017-03-30 Commission opinion and order imposing remedial sanctions (Release No. 33-10331)
Primary documents
Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.