SEC v. Total Wealth Management and Jacob Keith Cooper (2015)
Judgment entered
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In August 2015 an SEC administrative law judge permanently barred adviser Jacob Keith Cooper and ordered about $1.82 million in disgorgement plus interest and a $780,000 penalty, over undisclosed revenue sharing and weak due diligence at Total Wealth Management, Inc.
The record
| Agency | SEC |
|---|---|
| Release number | 3-15842 |
| Date filed | 2015-08-17 |
| Date resolved | 2015-08-17 |
| Court | SEC administrative law judge |
| Status | judgment |
| Asset class | bonds |
| Criminal parallel | No |
| Bars imposed | registration bar |
| Defendants | Total Wealth Management, Inc. ; Jacob Keith Cooper ; Nathan McNamee ; Douglas David Shoemaker |
| Cited as charged or alleged | Advisers Act s.206 ; Exchange Act s.10(b) and Rule 10b-5 ; Securities Act s.17(a) |
| Techniques |
What was ordered
- Civil penalty
- $780k
- Disgorgement
- $1.8m
- Prejudgment interest
- —
- Total relief
- $2.6m
- Alleged gain
- —
What is alleged to have happened
The decision covers Cooper only; the proceeding was stayed for Total Wealth, Nathan McNamee and Douglas David Shoemaker pending settlements. The Division proved violations in recommending client investments while taking undisclosed revenue-sharing payments. Disgorgement is $982,057.72 plus $833,935.27, with interest, and the sums go to a Fair Fund.
The decision mentions that one investment, Life's Good, was later revealed as a Ponzi scheme run by a third party, which Cooper had not examined properly. That is a due-diligence failure on another person's scheme, not a Ponzi scheme the respondents operated, so the ponzi-schemes tag has been removed. The earlier record also listed one name as "Total Wealth Management, Inc. Cooper".
Timeline
- 2015-08-17 Initial decision
Primary documents
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