The Non-Financial Ledger

Picture this: You spent years building savings. Maybe you inherited a little, worked overtime, cut vacations short. You found a real estate fund that mailed you a quarterly newsletter with charts showing steady 10% returns. The CEO appeared in YouTube videos telling you this was “steady, reliable, passive income.” He said his team had been doing this since 1997. He said their key people had worked together for more than a decade. He said you were “getting the security of a note with the yields of an equity investment.” You trusted him. You wired in your money.

What you did not know is that within months of handing over your check, the people you trusted were already moving investor money into companies they secretly owned, with no contracts explaining why. You did not know that the fund was failing to generate enough income to pay the returns you were promised, and that the shortfall was being covered by the next person who wired in their savings. You did not know you were the mark.

The monthly deposits kept arriving. That was the cruelest part. The fund’s own administrators flagged to management, nearly every month, that the fund was “short” on net income to pay what it owed investors. Management’s response was to change the accounting rules to make it look like there was more income. When that was not enough, they typed fake property sales into the books, including sales to a company that did not yet exist. They backdated the paperwork. They signed it. The deposits kept coming out of the accounts of the people behind you in line.

Around 500 people invested in this fund over its lifetime (according to the SEC at least). During the period the SEC focuses on, 272 equity investors put in approximately $46.7 million. They were told their money would go to work buying and renovating single-family homes. Instead, roughly one third of incoming investor money was immediately routed to pay people who had already invested. That is what a Ponzi scheme does: it turns your trust into the mechanism of your own betrayal.

None of the three people running this operation had ever run a fund before. The SEC’s complaint says so explicitly. Yet the official documents sent to investors implied the CEO had been leading the fund since its 2014 inception. The CFO’s bio claimed a finance degree and experience overseeing a $750 million asset portfolio. Neither claim was true. The people holding your money had fabricated the credentials that convinced you to hand it over.

Straight From the Complaint

The following are verbatim quotes from the SEC’s federal complaint filed April 20, 2026 in the Eastern District of California. Each quote is followed by a breakdown of what it proves.

“Rather than investing equity investor money as promised, Hardcastle, Giarmarco, and Medlock caused Voyager to use more than $15 million dollars in new equity investor money to pay current equity investors in Ponzi-like fashion.”

• This is the SEC’s core allegation, stated in the opening paragraph of the complaint. It establishes that incoming investor funds were diverted from their promised purpose: investing in real estate assets.
• The SEC uses the phrase “Ponzi-like” because the mechanics match the defining feature of a Ponzi scheme: using money from new investors to pay returns to existing investors, with no underlying profit generation to support those payments.

“During the Relevant Period, the Fund only earned sufficient net cash from investments or debt financing to pay an approximately 1% return, not the 10% Preferred Return owed to investors and claimed to have been made. New Equity Investor money comprised approximately 89% of the money used to pay the Preferred Return.”

• This figure directly contradicts the 10% annual return claimed publicly in investor newsletters, videos, and offering documents. The gap between 1% earned and 10% promised was not disclosed to investors at any point.
• The 89% figure means that for every dollar investors received as a monthly “return,” approximately 89 cents came from another investor’s principal, not from property income or debt proceeds.

“Beginning in approximately May 2022, Hardcastle and Medlock, acting on behalf of Voyager, began recognizing fake revenue in the Fund’s financial statements by entering ‘cash sales’ into the accounting general ledger for the sale of houses from the Fund to affiliated entities, when no cash had been received and the Fund retained control over the properties.”

• This describes an act of accounting fraud: recording revenue that did not exist. The fund’s own stated revenue recognition policy required cash to be received before a sale could be recognized. That policy was violated deliberately.
• The fake sales totaled approximately $8.2 million, enough to manufacture the appearance of sufficient income to justify paying the preferred return each quarter.

“At least one affiliated entity, The Golden H, LLC, was not formed until after the first purported cash sale had been entered into the Fund’s accounting general ledger.”

• This is direct evidence that the purchase agreements were fabricated retroactively. A sale cannot legally occur with a company that does not yet exist. The existence of a backdated sale to a non-existent buyer proves the documents were created to justify accounting entries already made.

“In the September 2020 PPM, Giarmarco, acting on behalf of Voyager, also made false and misleading statements about Giarmarco’s education and work history. Specifically, the September 2020 PPM stated that Giarmarco: graduated ‘from Fresno State with a B.S. in Finance’; and formerly had a ‘position as M&A Director and Vice President overseeing a $750ml asset portfolio.’ […] Giarmarco did not receive a Bachelor of Science in finance or graduate from college, and Giarmarco did not ‘oversee’ a $750 million asset portfolio.”

• These are fabricated credentials inserted into the official Private Placement Memorandum, the primary document investors received when deciding whether to invest. The CFO managing investor money lied about having a finance degree and invented a prior executive role overseeing three-quarters of a billion dollars in assets.
• Neither Hardcastle nor Giarmarco had prior experience running a fund. Investors were told the opposite.

“Hardcastle, acting on behalf of Voyager, stated that the Fund was ‘lending money to folks that we know that are brought to us from our property managers or people we know all backed with real estate…'”

• This quote is from the 2022 Annual Investor Meeting. “Folks we know” and “people we know” are phrases investors would naturally interpret as unaffiliated third parties. In reality, multiple loans the fund was making went to companies Hardcastle and Giarmarco personally owned. The SEC alleges this statement was false and misleading for that reason.

What You Were Told vs. What Was Happening

The SEC’s complaint documents a systematic gap between what Voyager communicated publicly and what internal records show was actually happening inside the fund.

• Investors were told in multiple versions of the Private Placement Memorandum that the fund’s manager would “attempt to invest the proceeds as quickly as prudence and circumstances permit.” The documented reality: more than $15 million of incoming equity investor money was used to pay existing investors rather than purchase assets.
• The PPMs stated that the preferred return would be paid “subject to the Fund’s performance and sufficient cash flow” and that Voyager “anticipates that revenues will be sufficient to create net profits.” The documented reality: the fund was generating only about 1% in actual investment returns, not the 10% claimed, and management was informed nearly every month that the fund was “short” on net income to cover what it owed investors.
• Hardcastle’s quarterly newsletters to investors repeatedly stated the preferred return was “earned and distributed.” The documented reality: approximately 89% of those distributions came from new investor money, not from earned income.
• A September 2021 YouTube podcast had Hardcastle stating the fund “has returned a ten percent return every year plus, since its inception in 2015.” The documented reality: during the period Hardcastle controlled the fund, it was not generating 10% returns from operations.
• The PPMs disclosed certain conflicts of interest under a “Conflicts of Interest” section and listed certain affiliated entities under “Affiliates of the Manager.” The documented reality: nine affiliated entities controlled by Hardcastle, Giarmarco, or Medlock received approximately $5.98 million in fund money through undisclosed transactions, and none of those entities were disclosed in the conflicts section or the affiliates list.
• The Operating Agreement promised investors that affiliated-party loans would be on “the same or similar terms” as loans to unrelated third parties. The documented reality: affiliated loans used an “Automatic Continuance” clause that allowed the principals’ own companies to defer repayment indefinitely, a term not given to outside borrowers. Most outside borrowers were also required to post real estate collateral; some affiliated loans had no collateral at all.
• The September 2020 PPM was sent to investors with an introductory letter signed by the prior CEO, and still listed that prior CEO as the “CEO” of Voyager in the key team members section, months after Hardcastle had purchased and taken control of the fund. Hardcastle’s own bio described him as a new hire focused on “management efficiencies,” not as the owner and CEO.
• The August 2021 and November 2023 PPMs, signed by Hardcastle, contained statements in the first person claiming “Since 1997, my team and I have closed over 11,000 purchases and sales of raw, vacant land, in 35 states” and “In early 2014, we launched Fund I.” These statements were originally written by the prior owner and described that person’s history, not Hardcastle’s. Hardcastle had them republished under his own signature without correction.

Profit-Maximization at All Costs

The SEC’s complaint documents a series of internal decisions made by the principals that prioritized extracting money from the fund over the interests of the investors whose capital they were supposed to steward.

• Within months of acquiring Voyager in July 2020, Hardcastle and Giarmarco began transferring fund money to companies they personally owned. Approximately $2.9 million went to affiliated entities with no contracts or supporting documentation explaining why the fund should have made those transfers at all.
• Another $3.05 million was routed to affiliated entities through 13 promissory notes. The terms of those notes, including the “Automatic Continuance” clause designed to defer repayment indefinitely, were set by Hardcastle himself as CEO. He was setting favorable terms for his own companies on loans drawn from investor capital.
• Voyager collected a 1.5% annual management fee from the fund throughout the period of the alleged fraud. Hardcastle and Giarmarco, as owners of Voyager, received a portion of those management fees. They were being paid to manage the fund at the same time the SEC alleges they were looting it.
• When the fund’s own administrator began notifying management nearly every month that there was not enough net income to cover investor distributions, the response was to change the accounting rules to make the income look bigger, not to stop the distributions or accrue the shortfall as required by the offering documents.
• Beginning in May 2022, Hardcastle and Medlock began entering approximately $8.2 million in fake property sales into the books, timed to coincide with quarter-end periods when the fund was finalizing distribution calculations. These were not honest mistakes in accounting; the SEC alleges the entries were coordinated with the timing of investor payment cycles.
• Audits for fiscal years 2022, 2023, and 2024 were never obtained, despite the offering documents requiring annual audits. The 2021 audit was significantly delayed because the auditor raised concerns about the capitalization changes. When the auditor tested the numbers, it found capitalized costs were overstated and required an adjustment that reduced the fund’s reported 2021 net income by approximately $1.9 million. Rather than course-correct, the flat 85% capitalization rate remained in place for at least fiscal years 2022 and 2023.

Regulatory Gray Zones

Parts of this scheme exploited structural ambiguities in how private fund oversight operates, creating gaps that allowed the fraud to continue for years before regulatory action.

• The fund was a private placement, meaning it was not required to register with the SEC as a public company. Private placements rely heavily on disclosures in offering documents like PPMs rather than ongoing SEC-reviewed filings. The SEC alleges that the defendants abused this framework by making those offering documents themselves false and misleading, which is the precise mechanism private placements depend on for investor protection.
• Annual audits were required by the fund’s own offering documents, but no external regulator automatically enforced that requirement in real time. The audit for fiscal year 2021 was delayed significantly due to the auditor’s own concerns about the capitalization changes. Audits for fiscal years 2022, 2023, and 2024 were never obtained at all. The absence of audits meant the fraudulent accounting changes went unchallenged by an outside auditor for at least two consecutive years.
• The “Automatic Continuance” clause inserted into affiliated-entity promissory notes did not openly prohibit repayment; it simply structured the loan so the fund was required to give 90 days’ written notice before it could demand repayment. Because Hardcastle and Giarmarco controlled both sides of the transaction, they could ensure that notice was never given. The mechanism was facially legal text in a private contract, not an obvious prohibition. Its function was to make investor-funded loans permanently interest-free and principal-free in practice.
• The capitalization policy change, moving from a case-by-case method to a blanket 85% capitalization rate for all rental home costs, exploited the discretion that accounting standards allow for estimating asset improvements. The auditor ultimately challenged this during the 2021 audit and required a $1.9 million downward adjustment, but the policy stayed in place for subsequent years when no audit occurred.