SEC v. North Dakota Developments, Gavin and Hogan (ponzi schemes, 2015)

Judgment entered

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The SEC's 2015 case over the Bakken 'man camp' offerings run by North Dakota Developments, Robert Gavin and Daniel Hogan ended in judgments entered on 24 April 2018 in the District of North Dakota. The court ordered Gavin to pay $350,000 in disgorgement, $24,613 in interest and a $500,000 penalty, and Hogan $1,250,000, $87,906 and $500,000. The company's own judgment was not read.

The record

What was ordered

Civil penalty

$1m

Disgorgement

$1.6m

Prejudgment interest

$113k

Total relief

$2.7m

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 complaint, filed in the District of North Dakota on May 5, 2015, alleges promised returns of up to 42 percent and guaranteed returns of up to 25 percent regardless of rental income, projects that were delayed or unprofitable, guaranteed returns paid from later investors' money, and over $25 million misappropriated to pay undisclosed commissions and other costs. The SEC obtained an emergency asset freeze.

The allegations are unproven. Ponzi-style payments are one of several alleged features; the core claim is an offering fraud. The record had split the defendants incorrectly across two entries.

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.

On 24 April 2018 the court entered judgment on the SEC's motion, after making findings of fact and conclusions of law. As to Gavin, it enjoined future violations of Section 5 of the Securities Act and ordered disgorgement of $350,000 with $24,613 in prejudgment interest and a third-tier civil penalty of $500,000. As to Hogan, it ordered disgorgement of $1,250,000, interest of $87,906 and a third-tier penalty of $500,000. The figures stored here add Gavin's and Hogan's amounts. These are court findings rather than a settlement. The two judgment documents I read cover the two individuals; I did not read the judgment for North Dakota Developments, LLC or for the relief defendants, and the figures in the SEC's wording of the original Ponzi-style allegations were not what the judgments rest on, which concern unregistered offers and sales.

For the regulator's own account of the facts, read the primary documents linked above. This page summarises the structured record and does not reproduce them.

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

1. 2015-05-06 Litigation release published
2. 2018-04-24 Judgments entered against Gavin and Hogan (D.N.D.)

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
• Judgment as to Robert L. Gavin (24 Apr 2018)
• Judgment as to Daniel J. Hogan (24 Apr 2018)

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.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added September 10, 2026. submit a correction.