Adam Nugent Barred by SEC Following Fraud Allegations

Adam Nugent (CRD #: 4549399), a broker formerly registered with Purshe Kaplan Sterling Investments, has been barred by the SEC, according to his BrokerCheck record, accessed on May 24, 2023. Keep reading to learn more about his alleged conduct as a broker.

Bar by SEC

On February 27, 2023, the Securities and Exchange Commission undertook cease-and-desist proceedings against Foresight Wealth Management (Foresight) and its founder and sole owner Adam Nugent.

The SEC alleged that they engaged in fraudulent activities with regard to the management of private fund Agronomic Capital, LP (AG Capital) and the cannabis-related holding companies it was allegedly invested in, Agronomic Holdings, LLC (AG Holdings) and Agronomic Enterprises, LLC (AG Enterprises).

Foresight and Adam Nugent allegedly raised approximately $19.5 million from more than 80 investors, many of whom were allegedly their advisory clients, through offerings of AG Capital’s limited partnership interests and promissory notes.

Further, the SEC alleged that Adam Nugent and Foresight defrauded AG Capital and its investors by misusing fund assets, failing to disclose conflicts of interests, breaching AG Capital’s limited partnership agreement, and misrepresenting to investors how the proceeds of their investment in AG Capital would be used.

Alleged Proposed Amendment to Limited Partnership Agreement

Adam Nugent and Foresight allegedly sought a proposed amendment to AG Capital’s limited partnership agreement that would grant “profit interests” to converted syndicate investors that would effectively give those investors an economic interest in AG Capital.

In 2020, Adam Nugent and Foresight allegedly informed all existing limited partners that an amendment to the agreement was necessary. However, they allegedly failed to disclose anything about these syndicate investors to the limited partners, including the consequences of granting them profit interests.

Instead, they allegedly claimed that the amendment was necessary due to AG Capital’s increased ownership position in AG Enterprises.

Foresight and Adam Nugent allegedly also falsely stated that the amendment would not “disadvantage” limited partners, when the amendment would in fact obligate limited partners who contributed cash in exchange for their interests to share AG Capital’s profits with the converted syndicate investors.

The SEC concluded that, through this alleged misconduct, Foresight Wealth Management and Adam Nugent willfully violated the following regulations:

• Section 17(a) of the Securities Act of 1933
• Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder
• Sections 206(1), 206(2), and 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-8 thereunder

Securities Act of 1933

Section 17(a) of the Securities Act of 1933 prohibits the use of fraudulent schemes and devices relating to the purchase and sale of securities across state lines. In particular, it prohibits the use of false or misleading statements and the omission of facts concerning securities.

Securities Exchange Act of 1934

Section 10(b) of the Securities Exchange Act of 1934 bans manipulative, deceptive, and otherwise fraudulent activities relating to the securities business. Rule 10b-5 specifically prohibits false statements and omissions of fact that mislead investors.

Investment Advisers Act of 1940

Sections 206(1) and 206(2) of the Investment Advisers Act of 1940 prohibit the use of fraudulent and deceptive schemes or practices.

Section 206(4) prohibits fraudulent investment adviser marketing tactics, including the use of untrue statements or misleading omissions.

Sanctions

Starting February 27, 2023, Adam Nugent was permanently barred from associating with the following:

• Brokers
• Dealers
• Investment advisers
• Municipal securities dealers
• Municipal advisors
• Transfer agents
• Nationally recognized statistical ratings organization (NRSRO)

He was also barred from participating in penny stock offerings starting on the same date.

The SEC ordered Adam Nugent to perform undisclosed undertakings and to cease and desist from violations of the following regulations:

• Section 17(A) of the Securities Act of 1933
• Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder
• Sections 206(1), 206(2), and 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-8 thereunder

The SEC also imposed the following monetary sanctions:

• Total fines of $1,379,061
• Total disgorgement of $1,379,061
• Other monetary sanctions totaling $280,003

Background Information

Adam Nugent has passed the following exams:

• Series 66 – Uniform Combined State Law Examination
• SIE – Securities Industry Essentials Examination
• Series 7 – General Securities Representative Examination

He previously worked for the following firms:

• Purshe Kaplan Sterling Investments (CRD#:35747)
• Securities Service Network (CRD#:13318)
• Hornor, Townsend & Kent (CRD#:4031)

Kurta Law Can Help

If you worked with Adam Nugent and you have concerns about your investments, please contact us today at 877-600-0098 or info@kurtalawfirm.com for a free consultation.

For over 20 years, Kurta Law has advocated on behalf of investors who want to recover their investment losses from brokers and brokerage firms. Kurta Law is a nationally recognized law firm and exclusively represents investors against brokers and brokerage firms on a contingency basis. This means that the firm only earns a fee if our securities attorneys recover money on your behalf.