Mammoth Value Fund SEC Review: Why the $17.6 Million Filing Needs More Explanation Than It First Appears
INDEPENDENT VERDICT
Mammoth Value Fund LLC is not an anonymous internet investment vehicle. Its October 5, 2026 Form D reports $17.6 million sold to 22 investors, a first sale on January 26, 2026 and an $800,000 minimum investment. Further research connects the offering to the Crestwood rural EB-5 project in Mammoth Lakes, California, promoted by Paragon Capital Group. Paragon describes Crestwood as a 69-residence luxury development and currently states that the EB-5 portion has been fully subscribed. Those are meaningful verification points. But the deeper filing also produces several issues that should not be skipped: the Form D says the offering runs in parallel with a Regulation S offering, states that the amount sold specifically under Regulation D is indeterminable, discloses an $80,000 expense amount per unit and references fees of up to 4.75% annually. The Delaware address shown on the SEC filing is also the address of a commercial registered-agent provider rather than evidence of an operating investment office. These facts do not establish wrongdoing, but they make the structure and fee economics considerably more important than the headline "$17.6 million raised."
THE $17.6 MILLION NUMBER HAS AN IMPORTANT QUALIFICATION
At first glance, the Form D looks unusually clean: 22 investors multiplied by the $800,000 minimum equals exactly $17.6 million. But the issuer includes an important clarification. The offering is being conducted in parallel with a Regulation S offering, the aggregate offering amount across the structures is stated as $60 million, and the filing says that the aggregate amount actually sold under Regulation D cannot currently be determined. That means it would be too aggressive to describe $17.6 million simply as a clean, stand-alone U.S. Reg D fundraising total without explaining the parallel structure.
This matters particularly because the investment appears designed for the EB-5 immigrant-investor market, where many participants are located outside the United States and securities can be offered through Regulation S structures. Paragon's current Crestwood project page reports a $50.4 million EB-5 capital raise, equal to 63 investors at $800,000 each, and describes the project as fully subscribed. The October 5 Form D, by comparison, reports 22 investors and $17.6 million. These figures are not necessarily contradictory: offshore Regulation S subscriptions, timing differences or separate securities channels could account for much of the gap. But an investor conducting diligence should reconcile the Form D, Regulation S subscriptions and current $50.4 million sponsor-reported total rather than treating all three figures as interchangeable.
THE $80,000 FEE IS TOO LARGE TO TREAT AS A FOOTNOTE
One of the strongest negative-diligence points comes directly from the filing data. The offering reports an $80,000 expense amount per unit alongside the $800,000 investment minimum, as well as fees that may reach 4.75% annually. An $80,000 charge is equal to 10% of the $800,000 investment amount before considering any continuing fees. Independent marketing material for Crestwood likewise describes an $800,000 EB-5 investment plus an $80,000 administrative fee.
The existence of an administrative fee is not unusual in EB-5 offerings, where regional-center administration, immigration-program compliance, securities work, investor servicing and other costs can be substantial. The key question is what investors actually receive for the fee and whether it is refundable under any circumstances. Investors should determine whether the $80,000 is paid entirely outside the investment capital, whether all or part goes to the manager or sponsor, whether migration agents or overseas introducers receive compensation from it, and exactly what the referenced annual fee covers.
The distinction is especially important because immigration and investment economics are separate. Obtaining USCIS immigration approval does not guarantee repayment of investment principal, and a successful real-estate project does not automatically guarantee an immigration petition outcome for every investor.
CRESTWOOD CAN BE IDENTIFIED — AND IT IS A CONCENTRATED REAL-ESTATE BET
Public sponsor materials identify Crestwood as a rural EB-5 real-estate development in Mammoth Lakes, California consisting of 69 luxury residences on approximately 7.3 acres near Sierra Star Golf Course and Mammoth Mountain. Paragon currently describes total project costs of approximately $133.7 million and an EB-5 raise of $50.4 million, and says the EB-5 financing is structured as a first-position senior secured loan.
Those protections are meaningful if documented and enforceable, but the investment remains exposed to a concentrated real-estate project. Investors are relying on construction completion, development budgets, home-sale demand, pricing in a luxury resort market, borrower performance and the enforceability and value of collateral. A "first-position" security interest can improve creditor priority, but it does not mean principal cannot be lost. If development costs increase significantly or the collateral value falls below outstanding obligations, senior status does not manufacture sufficient asset value to repay investors.
The Form D also does not independently establish the value of the underlying land, construction completion percentage, presale levels, loan-to-cost ratio or developer equity actually funded. Those figures should be reconciled against the PPM, loan agreement, appraisal, title records and current construction reporting.
THE DELAWARE ADDRESS IS NOT AN OPERATING-OFFICE VERIFICATION
Another useful piece of negative due diligence involves the issuer's address. Mammoth Value Fund lists 16192 Coastal Highway, Lewes, Delaware 19958. That exact address belongs to Harvard Business Services, Inc., a Delaware incorporation and registered-agent provider. Harvard Business Services itself publicly identifies 16192 Coastal Highway as its physical and registered-agent address.
This does not make the filing suspicious. Thousands of legitimate Delaware entities use commercial registered-agent addresses. But it means the address should not be presented as evidence that Mammoth Value Fund maintains an investment-management office in Lewes.
The same address and telephone number also appear on other filings signed by David Bosworth, including PCG Fund 11 LLC and the earlier Paragon Group 10 LLC filing. That provides a trail connecting Bosworth-controlled or sponsored fundraising entities, while simultaneously showing why the Delaware address itself is more administrative than operational.
DAVID BOSWORTH AND PARAGON PROVIDE A REAL SPONSOR TRAIL
The Mammoth Value Fund filing is signed by David J. Bosworth as manager. Paragon Capital Group's own management page identifies David Bosworth as Managing Partner and describes more than a decade of EB-5 experience. The firm says it has operated since 2011, served more than 500 investors and participated in more than $1 billion of real-estate projects. Those figures are sponsor claims and should be treated as such rather than as independently audited performance statistics.
Paragon also publishes a track record covering prior EB-5 projects, including Mammoth Lakes developments, and says Crestwood is its fourth project in that market. This gives Mammoth Value Fund a much more identifiable sponsor history than a newly created manager with no visible operating background.
However, FilingDossier did not identify a clean fund-specific Form ADV match showing Mammoth Value Fund Manager LLC as an SEC-registered investment adviser. That should not automatically be viewed as a violation because EB-5 fund structures, real-estate sponsors and regional-center entities can operate under regulatory frameworks different from a conventional registered asset-management business. It simply means investors should not call Mammoth Value Fund Manager an SEC-registered RIA unless the precise registration basis is independently established.
ONE SEC WARNING WITH A SIMILAR NAME SHOULD NOT BE MISATTRIBUTED
A deeper search produces an SEC PAUSE alert for an entity called Paragon Capital Group, Inc. This is exactly the kind of search result that can lead to a serious false accusation if names are matched mechanically.
The SEC alert concerns an entity using a New York address and the website `paragoncapitalgrp.com`, which the SEC said was impersonating another genuine securities firm. The Crestwood sponsor reviewed here uses `paragoncapgroup.com`, identifies different operating details and is associated with David Bosworth's EB-5 activities. On the evidence reviewed, the SEC PAUSE entity should not be treated as the same organization simply because both use the words "Paragon Capital Group."
This distinction is important. Proper negative due diligence means finding adverse records and also proving whether they actually belong to the entity being reviewed.
THE EB-5 PROMISE NEEDS TO BE SEPARATED FROM THE INVESTMENT PROMISE
Paragon markets Crestwood as a Rural TEA EB-5 project, which can offer immigration-processing advantages under the current EB-5 framework. The sponsor also highlights projected job creation and historical immigration-approval performance. But none of those statements means investors receive a guaranteed green card or guaranteed return of their $800,000 investment.
An EB-5 investor is taking two distinct risks. The first is immigration risk: whether the petition and project continue satisfying applicable USCIS requirements. The second is investment risk: whether the underlying borrower and real-estate project generate sufficient cash to return investor capital under the offering documents.
Those risks can diverge. A project could meet job-creation requirements but experience weak investment returns. Conversely, a commercially successful project does not eliminate individualized immigration-adjudication risks.
WHAT WE WOULD VERIFY BEFORE SENDING $880,000
The economic commitment appears to be materially larger than the headline minimum. An investor considering an $800,000 EB-5 investment plus the disclosed $80,000 administrative or expense amount should obtain the complete PPM, subscription agreement, operating agreement and loan documents before transferring funds.
The review should specifically reconcile the $60 million Form D offering figure with Paragon's currently reported $50.4 million EB-5 raise; identify every Regulation D and Regulation S vehicle participating in the transaction; show the complete use of the $80,000 fee; explain the "up to 4.75%" annual charge; identify the escrow or subscription-account arrangement; confirm the first-priority security interest through actual loan and lien documentation; establish who controls distributions; and provide current construction, appraisal and capital-stack data.
Investors should also confirm the exact regional-center entity and the project's USCIS filing status rather than assuming that a sponsor's prior I-956F approvals automatically apply to Crestwood. A prior Paragon Mammoth project, Obsidian, publicly received I-956F approval, but that is a different project and should not be used as evidence that Crestwood has received the same approval unless Crestwood-specific documentation confirms it.
FINAL ASSESSMENT
Mammoth Value Fund LLC has several substantial legitimacy signals. The SEC Form D is real, the offering reports $17.6 million and 22 investors, the $800,000 minimum aligns exactly with the current EB-5 investment threshold used in the project materials, David Bosworth can be connected to an established EB-5 sponsor, and Crestwood is a publicly identifiable Mammoth Lakes development rather than an unexplained fund name.
But the negative diligence is equally important. The reported $17.6 million cannot simply be equated with the full capital raise because the filing explicitly references a parallel Regulation S offering. The public sponsor figure has already reached $50.4 million and "fully subscribed," requiring reconciliation across vehicles. Investors face an $80,000 additional expense amount and potentially significant continuing fees. The SEC-listed Delaware address is a registered-agent address, not proof of an operating office. And the underlying investment is concentrated in a luxury real-estate development whose repayment ultimately depends on project economics and enforceable security—not on Form D or EB-5 status.
Our current assessment is therefore a verifiable EB-5 offering with a recognizable sponsor and identifiable real-estate project, but with unusually important fee, cross-border offering and capital-structure questions that should be resolved from the actual offering documents.
No evidence reviewed establishes that Mammoth Value Fund LLC is a scam or that the issuer has been charged with fraud. The stronger investor warning is more specific: SEC filing, USCIS-related project status and sponsor track record do not guarantee repayment of the $800,000 principal, an immigration result, or the accuracy of every marketing claim.