SEC v. National Realty Investment Advisors LLC, Rey E. Grabato II, Daniel Coley O'Brien, Thomas Nicholas Salzano and others (ponzi schemes, 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.
In October 2022 the SEC charged National Realty Investment Advisors LLC, Rey E. Grabato II and 5 others. The complaint alleges that NRIA and four former executives ran a Ponzi-like scheme raising about $600 million from roughly 2,000 investors, paying distributions from other investors' money and falsifying fund financials. Budinska and Samul are named as relief defendants; the officer-and-director bars are sought, not imposed.
The record
| Agency | SEC |
|---|---|
| Release number | LR-25558 |
| Date filed | 2022-10-14 |
| Court | U.S. District Court, District of New Jersey |
| Status | filed |
| Criminal parallel | No |
| Defendants | National Realty Investment Advisors LLC ; Rey E. Grabato II ; Daniel Coley O'Brien ; Thomas Nicholas Salzano ; Arthur S. Scutaro ; Olena Budinska ; Jamie A. Samul |
| Cited as charged or alleged | Exchange Act s.10(b) and Rule 10b-5 ; Securities Act s.17(a) |
| Techniques | Ponzi schemes |
What was ordered
- Civil penalty
- —
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- —
- Alleged gain
- —
What is alleged to have happened
The Securities and Exchange Commission announced this matter on October 14, 2022 as release LR-25558. The complaint alleges that NRIA and four former executives ran a Ponzi-like scheme raising about $600 million from roughly 2,000 investors, paying distributions from other investors' money and falsifying fund financials. Budinska and Samul are named as relief defendants; the officer-and-director bars are sought, not imposed.
This library tags the matter as a Ponzi scheme because the document describes returns to earlier investors paid from later investors' money, as alleged or found. The tagging is ours, not the regulator's: agencies charge statutory provisions, not technique names.
A parallel criminal proceeding is referenced. Civil and criminal outcomes are recorded separately, because they resolve on different standards of proof.
This matter is at the allegation stage. Nothing in the regulator's filing has been proven, and the respondents are entitled to the presumption that it has not been.
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
- 2022-10-14 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 |