The intersection of affinity fraud and Ponzi schemes is a recurring theme in securities enforcement. Although each theory is distinct, they frequently appear together in SEC enforcement actions.

In today’s article, we examine the SEC’s enforcement action against Wisdom Capital Management Group Ltd., an entity that claimed to be an Exempt Reporting Adviser (“ERA”) under the Investment Advisers Act of 1940 (“Advisers Act”). While ERAs are exempt from SEC registration, they remain subject to the SEC’s examination authority and must provide accurate, verifiable disclosures.