A.G. Morgan looted $138 million from retirees

The Non-Financial Ledger: What $123 Million in Losses Actually Means

The SEC complaint in this case is 29 pages of legal language, citation numbers, and paragraph references. Strip all of that away and what you have is a story about trust. Camarda and McArthur were not strangers cold-calling people from a boiler room. They were registered investment advisers — licensed professionals with fiduciary duties, people who were legally required to put their clients’ interests first. Many of the victims were already their clients. Some had been for years. These were people who had been showing up to meetings, handing over their account statements, trusting these men with the most intimate details of their financial lives.

Investor 9 was 78 years old when McArthur told him the Omni Diversified Fund III was “conservative.” He trusted that. He invested $150,000. He did not read the risk warnings in the offering documents because his adviser — his fiduciary — had already told him it was safe. That money is almost certainly gone.

Investor 4 was a widow with three young children. In March 2021, McArthur told her the Windsor Fund II was “low risk.” She invested $195,000. That could have been rent, college tuition, groceries for years. The fund collapsed. The money stopped coming back.

Investor 11 invested $660,000 in March 2021. That is a life’s work of savings. Camarda told her it was not risky. He did not even give her the offering documents. He mailed her signature pages — just the pages he needed her to sign — with no disclosure of what she was actually agreeing to. She signed because she trusted him.

Investor 8 invested $591,000 in the Omni Diversified Fund in November 2023. By that point, Camarda already knew Millennium was in financial trouble. He had known since April of that year. He told Investor 8 it was “safe” anyway. Within two days of that deposit clearing, Camarda transferred $400,000 of that money into his personal bank account.

The complaint does not record the names of these people, and we will not speculate about them. But it records what they told their advisers: they were retired, or close to it. They wanted conservative investments. They explicitly said they could not afford to lose their principal. They communicated the most vulnerable financial fact a person can communicate to someone in a position of professional trust — and that trust was used as a weapon against them.

When Millennium stopped paying in January 2024 and the whole structure fell apart, these investors did not get a bailout. They got irregular, infrequent payments that dwindled and stopped entirely by August 2024. The Wilshire Fund investors — the ones whose money went to Camarda’s son’s coffee shop — stopped receiving anything by May 2024. The coffee shop is called Buzz’d. It is located in North Bellmore, New York. It is not a diversified investment portfolio. It is a single drive-thru coffee stand, formed in February 2021, wholly owned by the CEO’s son. Retired people’s life savings funded it.

Legal Receipts: What the SEC’s Complaint Actually Says

These are direct quotes from SEC Complaint Case 2:26-cv-01986, filed April 3, 2026, in the Eastern District of New York. Every word below is from the source document.

“Defendants fraudulently induced hundreds of their financially unsophisticated and elderly clients to move large portions of their savings into high-risk private equity funds. Defendants knew investing in the funds was highly risky, but falsely told their clients the investments were safe. When the high-risk funds failed, many investors lost all of the money they invested — which, for some, was their entire life savings.”

“Contrary to Defendants’ representations, four of the Funds invested entirely in a single, high-risk mining venture and one of the Funds invested entirely in a start-up, drive-thru coffee shop company owned and operated by Defendant Camarda’s son.”

“Defendants did not disclose to investors, through the Offering Documents or otherwise, and pursuant to their duties as investment advisers, that Defendants had a significant financial interest in recommending the Omni Diversified and Windsor Funds to their individual advisory clients (i.e., that they would receive the Spread).”

“From April 2023 through December 2023, on at least 14 occasions, Camarda transferred offering proceeds from the Omni Diversified and Windsor Funds’ bank accounts to his personal bank account.”

“Camarda’s and McArthur’s representations to investors regarding the risk profile of the Funds were false and misleading because, in fact, these investments were highly risky. Among other things, the Confidential Offering Memoranda indicated that the Notes were unsecured loans to the Funds and that the Funds would invest in highly speculative, high-risk business ventures that had a high propensity for total failure.”

Public Deception: What Investors Were Told vs. What Was Actually Happening

The SEC complaint documents a systematic gap between the representations made to clients and the reality of the investments they were purchasing. These are specific, documented contrasts drawn directly from the court filing.

• Claim: The funds were “safe,” “conservative,” “low risk,” “no risk,” and investors “would never lose their money.” Reality: The offering documents — controlled by Camarda and McArthur — stated explicitly that investments “involve a high degree of risk” and that “each investor’s risk with respect to this Offering includes the potential for a complete loss of his or her investment.” Camarda and McArthur said one thing in person and the opposite in writing.
• Claim: The Windsor Funds would invest in “several diverse areas”: mining, real estate, merchant cash advances, and financial planning firms. Reality: The Windsor Funds invested solely in a single mining company, Millennium Holdings, a Wyoming LLC that purports to specialize in coal, rare earth elements, and limestone operations.
• Claim: The Omni Diversified Funds would use “careful selection of investments across a range of opportunities within the mining industry.” Reality: Both Omni Diversified funds invested in one company: Millennium. There was no selection process, no range, and no diversification.
• Claim: The Wilshire Fund would provide loans across “a range of opportunities within the food service industry.” Reality: The Wilshire Fund was created for the sole purpose of funneling money to Buzz’d, one coffee shop owned by Camarda’s son, with no other borrowers.
• Claim: Compensation disclosures in the offering documents purported to fully describe how the Fund Managers and defendants would be paid. Reality: The documents never disclosed that Camarda and McArthur would pocket the spread between Millennium’s 17% interest rate and the 9–11% paid to investors — the mechanism that generated at least $2.97 million for the defendants.
• Claim: The Wilshire Fund documents noted that borrowers “may include” family members of the fund manager. Reality: The fund was never designed to lend to anyone other than Camarda’s son. The word “may” was deliberate cover for an arrangement that was already certain before the first dollar was raised.
• Claim: Investor Questionnaires documented each investor’s financial sophistication and suitability. Reality: For at least some investors — including a 78-year-old retiree and a 71-year-old retiree — Defendants provided pre-filled questionnaires that overstated the investors’ financial knowledge and experience without the investors completing them.

Profit-Maximization at All Costs: The Math of the Scheme

The financial architecture of this alleged fraud was designed from the beginning to extract maximum profit for Camarda and McArthur while presenting clients with a facade of modest, stable returns.

• The spread mechanism generated at least $2.97 million for Camarda and McArthur during the Relevant Period. The structure was simple: Millennium paid 17% interest on the notes the funds held. Clients received 9–11%. The 6–8% gap went directly to Camarda (90%) and McArthur (10%). Every dollar raised from clients increased Defendants’ income — regardless of whether the underlying investment was sound.
• Camarda alone controlled approximately $2.673 million of the spread (90% of $2.97 million), transferring portions to A.G. Morgan. This arrangement created a direct personal financial incentive to keep recruiting clients into the funds and to conceal any information that might cause clients to withdraw.
• When Millennium showed signs of failing in April 2023, Camarda did not warn his clients. He continued to actively recruit new investors and continued to describe the funds as safe — while simultaneously diverting incoming client deposits into his own personal bank account.
• In November 2023, Investor 13 deposited $770,000. Within two days, Camarda transferred $400,000 of that money to his personal bank account. The investor had been told the fund was safe. Millennium was already in financial distress. Camarda knew this.
• The total misappropriated to Camarda’s personal account from April through December 2023 was at least $1,028,500, across at least 14 separate transactions.
• The Wilshire Fund created an additional undisclosed financial benefit: while Defendants did not receive a spread on Buzz’d the way they did with Millennium, the fund was engineered specifically to benefit Camarda’s son’s business. The complaint identifies this as an undisclosed conflict that made their investment recommendations to clients regarding the Wilshire Fund “not disinterested.”

The Contractor Shield: How the Entity Web Was Built

Camarda and McArthur did not simply open one fraudulent fund. They built a layered corporate architecture — five separate funds, each with its own dedicated fund manager LLC — that created multiple layers between the investors and the people actually controlling every dollar.

• Each of the five funds had its own separate fund manager LLC. The Omni Diversified Fund Manager, Omni Diversified Fund III Manager, Windsor Capital Fund Manager, Windsor Capital Fund II Manager, and Wilshire Capital Fund Manager were all distinct Delaware limited liability companies. All five were owned and operated by Camarda and McArthur.
• A.G. Morgan, the SEC-registered investment adviser, sat at the top of this structure. Camarda was its sole owner, CEO, and chairman. McArthur was its president. The registered firm’s regulatory status lent legitimacy to the entire operation — and the firm collected a portion of the spread Camarda received.
• Each fund manager LLC was the “sole owner, manager and investment adviser” of its fund, according to the offering documents. This structure meant that every investment decision ultimately traced back to Camarda and McArthur, while the layering of entities created potential confusion about who was legally responsible for what.
• The offering documents stated that the fund manager would “receive compensation for its service.” What they did not state was that this compensation included the undisclosed spread between the rate Millennium paid and the rate investors received — because disclosing that would have revealed the conflict of interest at the heart of the scheme.
• The Wilshire Fund structure linked Camarda’s personal family directly to investor money. Camarda signed the Buzz’d promissory notes as CEO of the Wilshire Fund. His son signed as CEO of Buzz’d. The same man was on both sides of the transaction that was presented to clients as an arm’s-length investment.

Here is a Department of Justice press release on this scamming of elders for fact checking purposes

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