Minish “Joe” Hede and Kevin Graetz, Formerly of Paulson Investment Company, Charged by SEC Following Allegations of Selling Away

The SEC alleged that Hede and Graetz acted as unregistered brokers in the sale of securities issued by Belize Infrastructure Fund I, LLC.

The Sonn Law Group is investigating allegations that Minish Hede and Kevin Graetz committed misconduct. If you or a family member has suffered losses investing, we want to discuss your case. Please contact us today for a free review of your case.

paulson-investment-brokers-chargedOn August 21, 2020, the SEC announced charges against Minish “Joe” Hede (CRD#: 2389098) and Kevin Graetz (CRD#: 1935982) for allegedly “acting as unregistered brokers in the sale of securities issued by Belize Infrastructure Fund I, LLC (“Belize Fund”).” 

The SEC’s complaint alleged that Hede and Graetz sold approximately $9.6 million worth of Belize Fund notes to customers at the firm where they were employed at the time, despite the fact that the firm had already declined to approve the Belize Fund’s notes for offer and sale to customers. By selling a security that was not approved by the firm, Hede and Graetz are accused of engaging in “selling away”. 

Selling away is when a broker solicits a client to purchase securities not held or offered by the executing brokerage firm. Brokerage firms generally have lists of approved products that can be offered by their brokers to clients of the firm. These approved products have usually undergone due diligence screenings and have been identified by the firm’s screening personnel as solid products.

When a broker sells away from the firm’s list of approved products, they run the risk of selling something for which due diligence has not been completed. As a general rule, selling away is prohibited.

The SEC also alleged that Hede and Graetz profited through the commissions from the sales, while their customers suffered significant losses. The owner of the Belize Fund, Brent Borland, was charged in 2018 by the SEC based on allegations that Borland misappropriated more than $5.8 million in funds obtained from investors in Belize Fund notes and used the money to fund his family’s expensive lifestyle.

The SEC’s complaint, filed in the U.S. District Court for the Southern District of New York, alleges that Hede and Graetz violated the broker registration provisions of Section 15(a) the Securities Exchange Act of 1934. The SEC seeks injunctive relief, disgorgement of ill-gotten gains and prejudgment interest, and civil money penalties.

Both Hede and Graetz were barred by FINRA in November 2017 after failing to respond to requests for information.

Hede has eight other disclosures on his BrokerCheck report. Two customer disputes were denied and one was withdrawn.


November 2019 Customer Dispute


March 2019 Customer Dispute


April 2017 Employment Separation After Allegations


April 2017 Customer Dispute


June 1999 Customer Dispute

Gaetz has twenty-five other disclosures on his BrokerCheck report. Two customer disputes were denied, while two were closed with no action taken. Fourteen disclosures are judgement / liens against Gaetz.

March 2019 Customer Dispute


April 2017 Employment Separation After Allegations 


April 2017 Customer Dispute


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The Sonn Law Group is currently investigating allegations that Mark Wojno recommended unsuitable investments. We represent investors in claims against negligent brokers and brokerage firms. If you or your loved one experienced investment losses, we are here to help. For a free consultation, please call us now at 866-827-3202 or complete our contact form.