Market Manipulation. Search

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.

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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

Structured fields for this action, as recorded in our case library.
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 (individual) ; Wayne L. Palmer (individual)
Techniques Ponzi schemes

What was ordered

Civil penalty
$2m
Disgorgement
$67m
Prejudgment interest
—
Total relief
$68.9m
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 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.

Timeline

  1. 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.

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.

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

Record added September 10, 2026. submit a correction.