SEC v. Dow Rockwell LLC and Richard Dow Rockwell (2024)

Judgment entered

Checked against the primary document on October 3, 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.

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In December 2024 the SEC announced a judgment against Dow Rockwell LLC and Richard Dow Rockwell. Consent judgments of 25 November 2024 resolve a 2022 complaint alleging that the adviser and its owner failed to disclose compensation and a founder's conviction while recommending Professional Financial Investors, which the SEC says ran a Ponzi scheme. They owe jointly $402,075 in disgorgement, $121,844 in interest and an $80,000 penalty; the respondents are not charged with running the Ponzi scheme.

The record

Structured fields for this action, as recorded in our case library.
Agency	SEC
Release number	LR-26185
Date filed	2024-12-03
Date resolved	2024-12-03
Court	U.S. District Court, Northern District of California
Status	judgment
Criminal parallel	No
Defendants	Dow Rockwell LLC (entity) ; Richard Dow Rockwell (individual)
Cited as charged or alleged	Advisers Act s.206 ; Exchange Act s.15(a) ; Securities Act s.5 (statutes and rules cited in the document; not a finding that they were violated)
Techniques

What was ordered

Civil penalty: $80k
Disgorgement: $402k
Prejudgment interest: $122k
Total relief: $604k
Alleged gain: —

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

What is alleged to have happened

The Securities and Exchange Commission announced this matter on December 3, 2024 as release LR-26185. Consent judgments of 25 November 2024 resolve a 2022 complaint alleging that the adviser and its owner failed to disclose compensation and a founder's conviction while recommending Professional Financial Investors, which the SEC says ran a Ponzi scheme. They owe jointly $402,075 in disgorgement, $121,844 in interest and an $80,000 penalty; the respondents are not charged with running the Ponzi scheme.

This library does not tag the matter as a Ponzi scheme: on a source check, the document mentions Ponzi-like payments only in passing, or as part of another party's scheme, and the charges are about something else. The tagging is ours, not the regulator's: agencies charge statutory provisions, not technique names.

The relief recorded in our data is a civil penalty of $80,000, disgorgement of $402,075, prejudgment interest of $121,844, as the release or order states it. Penalty and disgorgement are distinct: disgorgement returns the gain, while the penalty is punitive. We store them separately so that aggregate figures across the library are not double-counted.

Timeline

2024-12-03 Litigation release published

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

The linked release is a work of the United States government and is not subject to copyright. Our summary and narrative above are our own writing.

Record added September 10, 2026. submit a correction.