SEC v. National Note of Utah and Wayne L. Palmer (ponzi schemes, 2015)
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.
In December 2015 the SEC announced it had won its case in the District of Utah against Wayne L. Palmer and National Note of Utah, a Ponzi scheme with more than 600 investors, with disgorgement of $66.96 million and civil penalties of $1.95 million.
The record
| Agency | SEC |
|---|---|
| Release number | LR-23419 |
| Date filed | 2015-12-04 |
| Date resolved | 2015-12-04 |
| Court | U.S. District Court, District of Utah |
| Status | judgment |
| Criminal parallel | No |
| Defendants | National Note of Utah, LC ; Wayne L. Palmer |
| Techniques | Ponzi schemes |
What was ordered
- Civil penalty
- $2m
- Disgorgement
- $67m
- Prejudgment interest
- —
- Total relief
- $68.9m
- Alleged gain
- —
What is alleged to have happened
The court found that Palmer promised a guaranteed 12 percent annual return and said the money was secured, but moved investor funds between accounts and used them to pay returns to other investors. Palmer must disgorge $1,767,287.10 and pay a $1,050,000 penalty; National Note must disgorge $65,188,155.83 and pay $900,000.
The record held only Palmer's disgorgement and penalty and a status of unknown; the two defendants' figures are now combined and the outcome is a judgment.
This library tags the matter as ponzi schemes because the document describes payments to earlier participants made from later participants' money. The tagging is ours, not the regulator's: agencies charge statutory provisions, not technique names.
What technique is this, and how does it work?
This action is tagged with one technique in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.
- Ponzi schemes — see how it works, what statute it engages, and every other action tagged the same way.
Timeline
- 2015-12-04 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.
Related actions
Other actions in the library sharing at least one technique tag with this one.
| Action | Agency | Filed | Technique | Penalty | Status |
|---|---|---|---|---|---|
| SEC v. Mark D. Hanf and Hoai-Nam Chu Phan (ponzi schemes, 2026) | SEC | 2026-09-04 | Ponzi Schemes | — | settled |
| SEC v. Leor Moshe, Jacob Goldman, Isaac Odes (ponzi schemes, 2026) | SEC | 2026-08-13 | Ponzi Schemes | — | filed |
| CFTC v. Goliath Ventures, Inc. and Christopher Delgado (ponzi schemes, 2026) | CFTC | 2026-08-11 | Ponzi Schemes | — | filed |
| SEC v. Goliath Ventures, Inc. and Christopher A. Delgado (ponzi schemes, 2026) | SEC | 2026-08-11 | Ponzi Schemes | — | filed |
| SEC v. Aras Investment Business Group S.A.P.I. de C.V. and others (ponzi schemes, 2026) | SEC | 2026-07-24 | Ponzi Schemes | $449k | judgment |
| CFTC v. Trevor L. Vernon and Argent Capital Management LLC (ponzi schemes, 2026) | CFTC | 2026-07-07 | Ponzi Schemes | — | filed |