The SEC has taken another step in the Raymond Lawrence Lent / The Putney Financial Group investor-compensation process by appointing a tax administrator for the Fair Fund created from Lent's 2024 settlement. The underlying case involved fiduciary-duty breaches by Putney, an unincorporated sole proprietorship of Lent, connected to third-party compensation received through an affiliated broker. The SEC found that from at least April 2016 through October 1, 2021, Putney recommended advisory-client investments that generated revenue sharing and sales commissions for the affiliated broker and for Lent as a registered representative, without fully and fairly disclosing the conflicts of interest. The September 2026 order is not a new fraud charge; it is part of the mechanics required to administer the investor-recovery fund.
U.S. Securities and Exchange Commission (SEC)
Official Release: https://www.sec.gov/files/litigation/admin/2026/34-106350.pdf
Related SEC Distribution Page: https://www.sec.gov/enforcement-litigation/distributions-for-harmed-investors/lent
NEWS:
The SEC's September 14, 2026 order appoints Heffler, Radetich & Saitta, LLP as tax administrator for the Fair Fund in the Raymond Lawrence Lent matter. The appointment follows the Commission's earlier May 20, 2024 settled administrative proceeding against Lent, doing business as The Putney Financial Group, Registered Investment Advisors. In that order, the SEC found that Putney breached fiduciary duties in connection with the recommendation and selection of investments that compensated an affiliated broker-dealer and Lent himself, without providing full and fair conflict disclosure to advisory clients.
The underlying conflict centered on variable annuity recommendations. According to the SEC's 2024 order, Putney recommended variable annuity investments from insurance companies that paid upfront sales commissions to Portsmouth Financial Services, Putney's affiliated broker, and to Lent in his capacity as a registered representative of that broker. The SEC found that, in many cases, the same insurance companies also offered variable annuities with the same features that did not pay commissions and had lower ongoing fees. That made the compensation structure central to the fiduciary-duty issue: clients needed clear disclosure that the adviser and affiliated broker had financial incentives to recommend higher-cost commission-paying products.
The monetary history shows how the case moved from enforcement to investor recovery. The Commission ordered Lent to pay $707,129.58 in disgorgement, $183,236.60 in prejudgment interest, $175,000 in civil penalty and $3,434.35 in post-order interest, for a total payment of approximately $1.0688 million. SEC distribution records state that Lent paid in full. In February 2025, the Commission created a Fair Fund using the money paid by Lent, plus any future interest, so the funds could potentially be distributed to harmed investors rather than simply retained as a penalty collection.
The 2026 tax-administrator order is a technical but important stage. Fair Funds often require tax reporting, interest allocation, escrow administration and compliance with federal tax rules before money can be distributed or fully administered. Appointing a tax administrator does not by itself identify final recipients or announce a completed distribution plan. It shows that the case has advanced into the infrastructure phase of fund administration, where settlement money must be handled, reported and prepared for possible investor distribution under future Commission-approved procedures.
WHY THIS CASE MATTERS:
The Lent / Putney case is useful because it illustrates how adviser conflicts can arise even when the recommended product is a conventional insurance or annuity product rather than an exotic private offering. The SEC's concern was not merely that variable annuities were recommended. The issue was that the adviser allegedly received compensation through an affiliated broker while comparable lower-cost versions were available, and clients were not given full and fair disclosure of the economic conflict.
The case also shows why investors should distinguish between a settlement order and the later recovery process. A headline penalty figure does not automatically mean harmed investors have already received money. Disgorgement, interest and penalties may first be collected, placed into a Fair Fund, assigned administrators and handled through tax and distribution procedures. For due diligence, the later Fair Fund orders can be just as relevant as the initial enforcement order because they show whether the case is moving toward remediation.
KEY POINTS:
- Raymond Lawrence Lent did business as The Putney Financial Group, Registered Investment Advisors.
- The SEC's original order involved fiduciary-duty breaches and undisclosed conflicts of interest.
- The conflict concerned third-party compensation, revenue sharing and sales commissions linked to advisory-client investments.
- The relevant period identified by the SEC ran from at least April 2016 through October 1, 2021.
- The SEC ordered Lent to pay approximately $1.0688 million in disgorgement, interest, civil penalty and post-order interest.
- Lent paid the ordered amount in full, according to SEC distribution records.
- A Fair Fund was created in February 2025.
- The September 14, 2026 order appoints Heffler, Radetich & Saitta, LLP as tax administrator.
- The new order concerns Fair Fund administration, not a new standalone allegation of misconduct.