SEC v. Andrew M. Middlebrooks, et al. (2022)

Alleged — pending

These are allegations. SEC has filed an action; nothing in it has been proven, and the respondents have not been found liable. Everything described on this page is what the regulator alleges, not what a court has found. See our editorial policy.

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 May 2022 the SEC announced emergency relief against Detroit hedge fund adviser EIA All Weather Alpha Fund I Partners and owner Andrew Middlebrooks over an alleged $39 million fraud, including false performance statements, falsified account statements and a fake audit opinion. A court granted a restraining order and asset freeze, with relief defendants named.

The record

Structured fields for this action, as recorded in our case library.
Agency	SEC
Release number	LR-25399
Date filed	2022-05-25
Court	U.S. District Court, Eastern District of Michigan
Status	filed
Criminal parallel	No
Defendants	Andrew M. Middlebrooks (individual) ; EIA All Weather Alpha Fund I Partners LLC (entity)
Cited as charged or alleged	Advisers Act s.206 ; Exchange Act s.10(b) and Rule 10b-5 ; Securities Act s.17(a) (statutes and rules cited in the document; not a finding that they were violated)
Techniques

What was ordered

Civil penalty: —
Disgorgement: —
Prejudgment interest: —
Total relief: —
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 SEC announced the case on May 25, 2022 (LR-25399) in the Eastern District of Michigan, covering mid-2017 to April 2022. New investor money was allegedly used for Ponzi-like payments to keep the appearance of profit, and Middlebrooks spent investor money on personal items such as jewelry.

The Ponzi tag is removed because the release describes a hedge fund fraud built on false statements and a fake audit, with Ponzi-like payments as a concealment tactic. The names were truncated and are corrected.

Timeline

2022-05-25 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.

SEC litigation release

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. If this matter has since resolved, been withdrawn or been dismissed, we want to know: submit a correction.