SEC Complaint
Case: 3:19-cv-00809 Document #: 1 Filed: 09/30/19 Page 1 of 101 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN __________________________________________ ) UNITED STATES SECURITIES ) AND EXCHANGE COMMISSION, ) ) Plaintiff, ) ) v. ) Case No. 19-cv-809 ) BLUEPOINT INVESTMENT COUNSEL , ) LLC, MICHAEL G. HULL, ) CHRISTOPHER J. NOHL, ) JURY DEMANDED CHRYSALIS FINANCIAL LLC, and ) GREENPOINT ASSET MANAGEMENT II ) LLC, ) ) Defendants. ) ______________________________________________________________________________ COMPLAINT Plaintiff, the United States Securities and Exchange Commission (the “SEC”), alleges as follows: Introduction 1. Michael G. Hull (“Hull”) and his entity, Greenpoint Asset Management II LLC, and Christopher J. Nohl (“Nohl”) and his entity, Chrysalis Financial LLC, perpetrated an offering fraud. Hull and Nohl through their entities manage Greenpoint Tactical Income Fund LLC (“Greenpoint Tactical Income Fund” or the “Fund”). From April 25, 2014 to June 2019, Hull, Nohl, and their entities raised approximately $52.783 million from approximately 129 investors in 10 states. 2. Hull is also the co-owner of Bluepoint Investment Counsel, LLC (“Bluepoint”), a now de-registered investment adviser that claimed to have as much as $145 million in assets under management. Bluepoint through Hull recommended that all of Bluepoint’s individual clients 1 Case: 3:19-cv-00809 Document #: 1 Filed: 09/30/19 Page 2 of 101 invest in the Greenpoint Tactical Income Fund and other affiliated Greenpoint Funds. Hull made these recommendations without regard for each individual investor’s needs and circumstances. 3. Hull, Nohl, and their entities are investment advisers to Greenpoint Tactical Income Fund and owe fiduciary duties to the Fund including a duty of loyalty.
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