The Non-Financial Ledger: What This Actually Cost

Numbers are how the SEC measures what happened here. They are not how the people on the receiving end will measure it.

Advisory Client 1 is a 77-year-old retired building contractor living on a fixed income. At 74, he told his financial adviser he wanted to leave $100,000 to his sister when he died. That desire — to take care of someone he loved on his way out — was the opening Brodacki used. The man wrote two checks, $50,000 each, and trusted that the money was growing somewhere safe. What he got back were monthly reports showing an account called “New England Note” steadily increasing in value, from $100,000 to $108,000 to $124,000 to $127,000. None of it existed. The company did not exist. The investment did not exist. His sister’s inheritance does not exist.

Advisory Client 2 is 73 and, on information and belief per the SEC complaint, terminally ill. She wanted something safe. She specifically asked for certificates of deposit. Brodacki steered her away from that and toward notes and bonds promising 6% to 8% interest. She sent $20,000 and received no paperwork, no confirmation, no proof of any purchase. She assumed, because she trusted him, that the investment was being handled. It was not. The first $10,000 was gone within 18 days.

Advisory Client 3 had known Brodacki for 24 years. She was not just a client. She considered him a friend. When she wrote four checks totaling $300,000 in May 2025, she believed she was investing in his business. She believed Castle Hill was successful because he had told her it was. She trusted the story he had built over two decades. Over the following two months, that $300,000 paid for $84,000 in tuition for his relatives, $65,000 to his in-laws, $66,800 in his credit card and loan payments, $14,900 in his travel, $14,000 in cash withdrawals, $9,000 in dining and entertainment, and $20,000 directly to Brodacki himself. The balance left in the account by the end of July 2025 was $1,600.

Client 7 is 85 years old. Client 5 is 84. Client 6 is 82. Client 18 sent $20,000 specifically for a high-yield account earmarked for their grandchildren. Client 17, a plumber, sent $195,000 across four transactions for retirement savings and a fund for his grandson. Not one of these people received a dollar back.

This was not a market downturn. It was not bad advice or poor judgment. Every dollar was taken on purpose. The fabricated statements, the invented companies, the lies about what went wrong with the prior employer — these were deliberate acts carried out against people who had every reason in the world to believe they were being protected.

Legal Receipts: What the Court Documents Actually Say

The following are direct quotations from the SEC complaint filed April 2, 2026. Case No. 3:26-cv-30055.

Public Deception: The Gap Between the Pitch and the Reality

Brodacki and Castle Hill maintained a systematic gap between what clients were told and what bank records show actually happened.

• Claimed: Client funds sent to Castle Hill would be invested in high-yield bank accounts, stocks, bonds, certificates of deposit, notes, or private company securities. Reality: Bank records show that little to none of the investment funds were used to make any investments.
• Claimed: Advisory Client 1 had a “New England Note” investment growing in value from $100,000 to $127,000 over two and a half years. Reality: The company “New England Note” does not exist, per the SEC complaint. The $100,000 was spent within one month on home improvement contractors, Brodacki’s personal account transfers, rent, credit cards, dining, and travel.
• Claimed: After being fired by the Registered Adviser in July 2025, Brodacki told at least one client he was no longer with the firm because it was trying to steal his clients. Reality: The Registered Adviser terminated Brodacki for “violation of firm policies and procedures and industry regulations and conduct,” per its public FINRA filing.
• Claimed: After termination, Castle Hill’s website still advertised a continuing relationship with the Registered Adviser. Reality: That relationship had been ended. Brodacki continued advertising the affiliation and soliciting clients until December 2025.
• Claimed: Advisory Agreements stated that “at no time will the Advisor accept, maintain possession or have custodial responsibility for the Client’s funds or securities.” Reality: Brodacki and Castle Hill instructed clients to write checks payable directly to Castle Hill and deposited those checks into bank accounts Brodacki personally controlled.

Profit-Maximization at All Costs: The Bank Record Breakdown

Castle Hill’s own bank records document how client money was converted to personal benefit. The following spending patterns are drawn directly from the SEC complaint.

• When Advisory Client 1’s $100,000 hit Castle Hill’s account, the entire balance was depleted within one month. Specifically: $44,000 in transfers to Brodacki’s personal account or cash withdrawals; $32,000+ for Castle Hill’s rent; $24,000+ to a home improvement contractor; $14,000+ in credit card and loan payments; $8,000+ for dining and entertainment; $4,000+ for travel. The ending balance: approximately $438.
• Advisory Client 3’s $300,000 was deposited in May 2025 and was almost entirely spent by July 31, 2025, leaving a balance of approximately $1,600. The spending included: $84,000+ in tuition for Brodacki’s relatives; $66,800 in credit card and loan payments; $65,000+ to Brodacki’s in-laws; $20,000+ paid directly to Brodacki personally; $14,900+ in travel; $14,000+ in cash withdrawals; $9,000+ in dining and entertainment.
• When Advisory Client 2’s second $10,000 check was deposited in August 2024, the Castle Hill account contained approximately $100. The money funded: personal account transfers leading to $2,600 in cash withdrawals; $2,800 in credit card and loan payments; $900 in office rent; $400+ in dining and entertainment; $250 in travel; and $2,100 applied to another client’s life insurance policy.
• Brodacki used client money to pay his mortgage, car-related expenses, vacations, and membership fees to exclusive social clubs, in addition to the expenses detailed above.
• The total amount taken across all 18 clients was $1,845,085.68. After accounting for $162,750 in partial repayments, the net loss to victims was approximately $1.68 million.

Regulatory Gray Zones: How the Structure Made This Easier

Brodacki operated inside a legitimate advisory structure for years, and that structure created gaps that made his conduct harder to detect and stop.

• From December 2017 to July 11, 2025, Brodacki and Castle Hill were not directly registered with the SEC. They operated as an independent financial adviser under a Commission-registered firm — the “Registered Adviser.” This meant Brodacki’s compliance oversight ran through that intermediary, not directly through the SEC. The Registered Adviser’s own compliance guidelines explicitly prohibited what Brodacki was doing, but those guidelines were only enforceable at the firm level, not by direct SEC supervision.
• The Advisory Agreements technically required all client assets to be held at an independent custodian. But when Brodacki instructed clients to write checks directly to Castle Hill, he was operating outside the custodial system entirely. Funds that never touched the custodian were invisible to whatever monitoring that custodian performed.
• Brodacki did not provide most of his 18 targeted clients with periodic account statements for the outside investments. The complaint notes that clients expected him to act in good faith and did not demand documentation. The absence of statement delivery meant there was no paper trail generating questions or complaints for years.
• After being fired in July 2025, Brodacki and Castle Hill were entirely unaffiliated with any registered adviser but continued soliciting and accepting investment funds through September 2025. The complaint notes this directly: they accepted funds from at least one client even when they had no regulatory affiliation at all. The gap between termination and enforcement — several months — allowed additional theft to occur.

How Delay Became a Tool: Seven Years of Uninterrupted Theft

The scheme ran from at least June 2018 to September 2025. The structure of trust and the absence of documentation made the delay possible.

• The complaint notes that most of the 18 targeted clients were not given periodic account statements for the outside investments. “Because of the advisory clients’ longstanding relationships with Brodacki and Castle Hill, and their trust in Brodacki and Castle Hill, the advisory clients expected Brodacki and Castle Hill to act in good faith on their behalf.” Trust replaced oversight, and Brodacki exploited that substitution for nearly seven years.
• For Advisory Client 1, fabricated account statements were delivered monthly for over two years, from at least February 2023 through at least July 2025. Each statement showing growth in the fictitious “New England Note” account reset the clock on suspicion. A client watching their investment “grow” month after month has no reason to demand an audit.
• The Registered Adviser only discovered Brodacki’s conduct when it investigated a specific instance of improper direct payment and terminated him in July 2025. The complaint does not identify what triggered that investigation. It does establish that over six years of scheme activity preceded that termination.
• Even after termination, Brodacki continued operating for months. He continued advertising via the Castle Hill website, continued claiming an affiliation that did not exist, and continued accepting money until at least September 2025. Castle Hill was not dissolved until December 31, 2025 — by the Commonwealth of Massachusetts, involuntarily.

Societal Impact Mapping: Who Gets Hurt When Advisers Go Rogue

Public Health and Vulnerable Populations

This case concentrated harm on people least equipped to absorb financial loss.

• At least six of the 18 clients are identified in the complaint as retired. Their ages range from 63 to 85. People in their 70s and 80s living on fixed incomes have no runway to recover from the loss of tens of thousands of dollars. There is no second career, no future salary, no time to rebuild. The theft is permanent.
• Advisory Client 2, aged 73, is described as terminally ill on information and belief. She invested $20,000 specifically seeking safety. That money is gone. Whatever purpose it was meant to serve in her remaining time cannot be served.
• Advisory Client 18, age 74, sent $20,000 earmarked for a high-yield account for their grandchildren. That inter-generational transfer of wealth was intercepted. The grandchildren receive nothing.
• Advisory Client 7 is 85 years old and sent $50,000 in March 2019 for an investment at Brodacki’s discretion. More than six years later, they have received zero repayment. No documentation. No investment. The money is gone.
• Advisory Client 1, 74 years old at the time of transfer, wanted to leave $100,000 to his sister. That legacy gift has been stolen. His sister will receive nothing from that specific intention.
• Advisory Client 3 has a documented 24-year relationship with Brodacki — not just financial, but personal. The complaint notes she considered him a friend. The betrayal here is not only financial. It is the destruction of a relationship that constituted a meaningful part of her adult life.

Economic Inequality

Brodacki’s spending patterns document a direct transfer of working- and middle-class savings into upper-class consumption.

• The clients of record include a retired building contractor, a retired engineer, a phlebotomist, a plumber, and a police officer. These are people who built savings incrementally through lifetimes of labor.
• That money was spent on exclusive social club memberships, lavish meals, vacations, home improvements, and $84,000 in tuition for Brodacki’s relatives, per the SEC complaint. The transfer of wealth was literal: from the savings accounts of working people into the lifestyle expenses of a man who positioned himself as their protector.
• Advisory Client 17 is a plumber who sent $195,000 across four transactions. That amount represents years of tradespeople’s savings. The stated purpose was retirement and a fund for his grandson. He received nothing back.
• Advisory Client 12 sent $303,585.68 in a single transaction in January 2023 to “overfund” a life insurance policy for future investment. That is the largest single transfer in the chart. The client received zero repayment.

The Settlement Isn’t Justice: What the SEC Can and Cannot Recover

The SEC is pursuing disgorgement, prejudgment interest, and civil penalties. The structural limits of this action mean full recovery for victims is unlikely.

• Brodacki died on March 23, 2026, before the complaint was filed on April 2, 2026. The SEC is pursuing his estate, not him personally. What the estate contains, and whether it can cover the $1.68 million in net losses, is not established in the complaint.
• Castle Hill was involuntarily dissolved by the Commonwealth of Massachusetts on December 31, 2025. The SEC is pursuing civil penalties against a dissolved LLC. The practical assets available to satisfy those penalties are unknown from the source document.
• The complaint seeks disgorgement of “ill-gotten gains” plus prejudgment interest. Disgorgement in SEC enforcement is a return of profits from the misconduct — it is not a compensatory damages mechanism for victims. Whether individual clients receive any money is determined by a separate distribution process, not guaranteed by the disgorgement order itself.
• Most of the $1.845 million was spent. Bank records show the account balances were reduced to near zero repeatedly. Recovering spent money requires locating assets in Brodacki’s estate. The tuition, home improvements, and cash withdrawals documented in the complaint are already gone.
• The SEC complaint does not include a count against the Registered Adviser, despite the fact that Brodacki operated under that firm’s supervision for the majority of the scheme period. Whether the clients have civil recourse against that firm is not addressed in this document.