SEC v. John W. Pauciulo, Esq. (2022)
Settled
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.
In July 2022 the SEC settled with Pennsylvania attorney John Pauciulo over the Par Funding scheme, finding he wrote misleading private placement memoranda and told investors the funds were exempt from registration when he knew or should have known a general solicitation made them ineligible. He agreed to a $125,000 penalty and a practice bar with a five-year right to apply.
The record
| Agency | SEC |
|---|---|
| Release number | 3-20926 |
| Date filed | 2022-07-07 |
| Date resolved | 2022-07-07 |
| Status | settled |
| Criminal parallel | No |
| Bars imposed | practice bar before the Commission (five years) |
| Defendants | John W. Pauciulo, Esq. |
| Cited as charged or alleged | Exchange Act s.10(b) and Rule 10b-5 ; Securities Act s.17(a) ; Securities Act s.5 |
| Techniques |
What was ordered
- Civil penalty
- $125k
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- $125k
- Alleged gain
- —
What is alleged to have happened
The Securities and Exchange Commission instituted and settled this proceeding on July 7, 2022 (Securities Act release 11080), without admission or denial by Pauciulo.
The order finds that he was the lawyer for Dean Vagnozzi's seven investment funds and about 25 other private funds raising money for Complete Business Solutions Group, doing business as Par Funding, a merchant cash advance business running an unregistered note offering from 2012 to 2020 and run behind the scenes by an undisclosed control person with a criminal history. Pauciulo prepared the memoranda and made presentations saying the offerings needed no registration and complied with the securities laws, though CBSG and some funds used general solicitation, such as radio ads and seminars, so no exemption was available. He violated Sections 5(a), 5(c) and 17(a) and Section 10(b) and Rule 10b-5.
He was ordered to cease and desist, denied the privilege of practising before the Commission as an attorney with a right to apply after five years, and to pay a $125,000 civil penalty to the receivership for Par Funding. The charge is the registration and exemption misstatements, not concealment of control, so the undisclosed-control tag is removed. The $490,000 on the record is a penalty the order mentions against another person, Vagnozzi, in a 2019 Pennsylvania settlement.
For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the release.
Timeline
- 2022-07-07 Administrative proceeding instituted (102e)
Primary documents
Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.