SEC v. DAVID J. FEINGOLD; JOSEPH B. BALDASSARRA; STEVEN S. BALDASSARRA; BROAD STREET GLOBAL MANAGEMENT, LLC; and BROAD STREET INC., No. 1:25-cv-20436-DPG, Southern District of Florida (Apr. 21, 2025) — Complaint

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.
SECURITIES AND EXCHANGE COMMISSION,
Plaintiff,
v. JURY TRIAL DEMANDED
DAVID J. FEINGOLD,
JOSEPH B. BALDASSARRA,
STEVEN S. BALDASSARRA,
BROAD STREET GLOBAL MANAGEMENT, LLC, and
BROAD STREET INC.,
Defendants, and
JOSEPHBENJAMIN, INC., and
JUST A NICE DAY, INC.
Relief Defendants.
_________________________________________/
COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF
Plaintiff Securities and Exchange Commission (the “SEC”) alleges as follows:
I.INTRODUCTION
1.The SEC brings this enforcement action to stop an ongoing offering fraud
perpetrated by David J. Feingold, Joseph B. Baldassarra, Steven S. Baldassarra, and the entities
they control – Broad Street, Inc. (“BSI”) and Broad Street Global Management (“BSG
Management”). Feingold, the Baldassarras, and their entities used deceptive schemes and
materially false statements to raise money from investors in Broad Street Global Fund, LLC
(“BSG Fund” or the “Fund”), a private equity fund that the Defendants used to raise more than
$1 billion from over a thousand investors. The SEC seeks temporary and preliminary relief,
1:25-cv-20436


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including an asset freeze and injunctions, as well as the appointment of a receiver, to put a stop
to Defendants’ misconduct.
2. BSG Fund is divided into numerous Series. BSG Management, which is the
investment adviser to the Fund, offered Series in Real Estate Infrastructure, Merchant Cash
Advances, Custom Home Building, Hotel Projects, and numerous other specialized areas. Each
of these Series is supposed to present an investor with a unique investment opportunity, with its
own unique possible profits and risk.
3.  However, Defendants engaged in a multi-faceted fraud related to BSG Fund.
First, Defendants fraudulently offered and paid inflated returns to investors in at least two major
Series, claiming that investments in Merchant Cash Advances – short term and fast funding
transactions to small business – generated significant profits when in fact they did not. As a
result, Defendants paid millions of dollars in returns to investors that were not supported by
actual MCA profits.
4. Second, the Defendants managed the Fund in a way that was inconsistent with
what they told investors and that materially increased investors’ risk. The Baldassarras and BSG
Management told investors that the Fund would follow certain structures and practices to protect
their investments: that they would keep the assets and liabilities of each Series separate, that
there would not be commingling of funds or assets between the Series, that there would be no
cross-liability between Series, and that the Fund would own the investments made with investor
funds. In fact, funds were commingled and cross-liabilities created, subjecting investors in one
Series to risks in other Series. Moreover, nearly all investor funds were diverted to accounts and
assets owned and controlled by BSG Management, the Baldassarras, or BSI. BSG Management
made almost no investments on behalf of the BSG Fund.


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5. Third, the Baldassarras and BSG Management made numerous false and
misleading statements to induce investors to invest with the Fund.  In addition to the
misstatements noted above, they falsely promised investors that a certain Series – related to
Qualified Small Business Stock – would generate tax-free returns, when in fact the funds were
not invested as promised and do not qualify for favorable tax treatment. They made false
statements about the Fund’s recordkeeping practices and financial statements. And finally, as
noted above, they misled investors about the profitability of the MCA investments.
6.  Fourth, Defendants engaged in additional deceptive conduct in their operation of
the Fund, all of which resulted in fraud on the Fund and its investors.
7.  In addition, the Baldassarras and BSG Management are investment advisers to
the BSG Fund, and thus have critical fiduciary obligations to their client, including duties of
loyalty and care, which impose on them an affirmative duty of utmost good faith, and an
obligation to provide full and fair disclosure of all material facts. Through the conduct alleged
below, the Baldassarras and BSG Management fell vastly short of these obligations.
8.   From the more than $1 billion that Defendants have raised, the Baldassarras
have transferred (or had investors send money to BSG Management directly) approximately
$880 million to BSG Management. From these funds, Feingold and the Baldassarras have
transferred approximately $170 million to the Baldassarras and to entities under the control of
Feingold or the Baldassarras.
9. By engaging in the conduct alleged in this complaint, Defendants Feingold,
Joseph Baldassarra, Steven Baldassarra, BSG Management, and BSI (collectively “Defendants”)
violated the antifraud provisions of Section 17(a) of the Securities Act of 1933 (“Securities Act”)
[15 U.S.C. § 77q(a)], and Section 10(b) of the Exchange Act of 1934 (“Exchange Act”) [15


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U.S.C. § 78j(b)], and Exchange Act Rule 10b-5(a) and (c) thereunder [17 C.F.R. § 240.10b-5(a)
and (c)]. In addition, Defendants BSG Management and the Baldassarras, violated the antifraud
provisions of Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)], and Exchange Act Rule
10b-5(b) thereunder [17 C.F.R. § 240.10b-5(b)]. The Baldassarras and Feingold are also liable as
control persons over BSG Management and BSI pursuant to Section 20(a) of the Exchange Act
[15 U.S.C. § 78t(a)].
10.  In addition, BSG Funds’ investment advisers, Defendants BSG Management and
the Baldassarras (collectively “BSG Fund’s Investment Advisers”), breached the fiduciary duties
they owed to the BSG Fund in violation of the antifraud provisions of Sections 206(1) and
206(2) of the Advisers Act of 1940 (“Advisers Act”) [15 U.S.C. §§ 80b-6(1) and 80b-6(2)].
11. Furthermore, Relief Defendants Josephbenjamin, Inc. (“Joseph Benjamin”),
owned and controlled by Joseph Baldassarra, and Just A Nice Day, Inc. (“Just a Nice Day”),
owned and controlled by Steven Baldassarra (collectively, “Relief Defendants”) have each
received substantial illicit proceeds from the Defendants’ fraud to which they have no legitimate
claim and under circumstances in which it is not just, equitable, or conscionable for them to
retain the funds.
II. PARTIES AND RELATED ENTITIES
a. Defendants
12. David J. Feingold, Esq. (“Feingold”), age 58, is a resident of Aventura, Florida.
Feingold is the Chief Executive Officer (“CEO”) of BSI and a control person over BSI and BSG
Management. The Baldassarras have delegated the management of many, including the largest,
business lines funded by BSG Fund, including real estate infrastructure projects and merchant
cash advance (“MCA portfolios”), to Feingold. Feingold is an attorney licensed in the state of


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Florida. In 1999, the Commission entered an order against Feingold to cease and desist from
committing or causing any violations of Section 5 of the Securities Act and Rule 10b-13 of the
Exchange Act.
13.  Joseph B. Baldassarra, age 48, is a resident of Simpsonville, South Carolina. He
is a managing member of BSG Management, the President of BSI, and a control person over BSI
and BSG Management. His responsibilities include: acting as investment adviser to the BSGF
Fund, along with Defendants BSG Management and Steven Baldassarra; soliciting investors for
BSG Fund; and supervising BSI’s internal sales staff who, among other things, solicit investors
for BSG Fund. Joseph Baldassarra was associated with several registered broker-dealers between
1998 and 2016.
14. Steven S. Baldassarra, age 49, is a resident of Simpsonville, South Carolina. He is
a managing member of BSG Management, the chief operating officer (“COO”) of BSI, and a
control person over BSI and BSG Management. His responsibilities include: acting as
investment adviser to the BSG Fund, along with Defendants BSG Management and Joseph
Baldassarra; and performing back-office functions for BSG Fund, including overseeing BSG
Fund’s and BSG Management’s bank accounts, and its accounting staff. Steven Baldassarra was
associated with several registered broker-dealers between 1998 and 2016.
15. Broad Street Global Management LLC (“BSG Management”) is a South Carolina
LLC that was formed on or about October 2018. BSG Management is the designated manager of
BSG Fund. BSG Management is owned and managed by the Baldassarras and is controlled by
the Baldassarras and Feingold. BSG Management (through the Baldassarras) acts as an
investment adviser with respect to BSG Fund. BSG Management has received approximately $9


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million directly from investors and more than $871 million from the bank accounts of BSG Fund
and BSG Series CM, LLC’s (“BSG CM Series”) bank accounts.
16. Broad Street Inc. (“BSI”) is a Delaware corporation that was formed on or about
June 2022. BSI’s voting shares are owned in equal parts by the Baldassarras and Feingold and
unanimity by all three is required for shareholder decisions. Since approximately June 2022
through the present, Feingold has been the CEO, Joseph Baldassarra has been the President, and
Steven Baldassarra has been the COO, of BSI. Feingold and the Baldassarras control BSI. BSI
has received more than $200,000, an interest in a registered broker-dealer, and ownership over
certain real estate assets.
A. Relief Defendants
17. Josephbenjamin, Inc. (“Joseph Benjamin”) is a South Carolina corporation owned
and controlled by Joseph Baldassarra. Through Joseph Benjamin, Joseph Baldassarra received
more than $65 million of illicit proceeds.
18. Just a Nice Day, Inc. (“Just A Nice Day”) is a South Carolina corporation owned
and controlled by Steven Baldassarra. Through Just a Nice Day, Steven Baldassarra received
more than $50 million of illicit proceeds.
B. Related Entities
19. Broad Street Global Fund LLC (“BSG Fund”) is a multi-Series Delaware LLC
that was formed on or about September 14, 2020. BSG Fund is a private equity fund. BSG Fund
has no managing board and thus cannot act for itself. Instead, BSG Fund’s operating agreement
vests all authority to act for BSG Fund in its manager BSG Management (or its agents). BSG
Fund has directly received more than $868 million from investors in exchange for limited
partnership interests in BSG Fund.


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20. Broadstreet Global Holdings, LLC (“BSG Holdings”) is a South Carolina LLC.
BSG Holdings is owned and managed by the Baldassarras. BSG Holdings receives funds to pay
the expenses for BSG Fund, BSG Management, and BSI. BSG Holdings has received more than
$134.5 million from BSG Management.
21. BSG Series CM, LLC (“BSG Series CM”) is a South Carolina LLC that is owned
and managed by the Baldassarras. BSG Series CM is related to one or more crypto asset mining
Series in the BSG Fund that is offered and sold by BSG Management and BSI. Its bank accounts
have received approximately $199 million from investors.
22. BSG Management, BSI, BSG Fund, BSG Holdings, and BSG Series CM are
referred to herein as the “Broad Street Entities.”
III. JURISDICTION AND VENUE
23. This Court has jurisdiction over this action pursuant to Sections 20(b), 20(d), and
22(a) of the Securities Act [15 U.S.C. §§ 77t(b), 77t(d), and 77v(a)]; Sections 21(d), 21(e), and
27(a) of the Exchange Act [15 U.S.C. §§ 78u(d), 78u(e) and 78aa(a)]; and Sections 209(d) and
214(a) of the Advisers Act [15 U.S.C. §§ 80b-9(d) and 80b-14(a)].
24. Defendants, directly or indirectly, singly or in concert with others, made use of
the means or instruments of transportation or communication in interstate commerce, the means
and instrumentalities of interstate commerce, or of the mails, in connection with the acts,
practices, and courses of business set forth in this Complaint.
25. This Court has personal jurisdiction over the Defendants and Relief Defendants
and venue is proper in the Southern District of Florida pursuant to Section 20(b), 20(d)(1), and
22(a) of the Securities Act [15 U.S.C. §§ 77t(b), 77t(d)(1), and 77v(a)]; Section 21(d) and 27 of
the Exchange Act [15 U.S.C. §§ 78u(d) and 78aa]; Sections 209(d) and 214(a) of the Advisers


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Act [15 U.S.C. §§ 80b-9(d) and 80b-14(a)]; and 28 U.S.C. § 1391(b) because, among other
reasons: (a) Defendant Feingold, CEO of Defendant BSI and an undisclosed control person of
Defendant BSG Management has resided in this district since at least June 2022; (b) Defendant
BSI has additional staff that work on behalf of the Broad Street Entities that reside in this district,
some of whom are also shareholders of Defendant BSI; (c) an accounting firm used by
Defendants is located in this district; (d) the home builder associated with BSG Fund’s custom
home sub-Series whose “nerve center” is located in this district has filed for bankruptcy in this
District; (e) more than 70 investors that have invested in the BSG Fund reside in this district; (f)
a registered broker used to solicit investors and is partially owned by Defendant BSI is located in
this district; and (g) many of the acts, practices, transactions, and courses of business alleged in
this Complaint occurred within this district.
IV.       FACTUAL       ALLEGATIONS
A. BSG Fund’s Formation, Operation, and Relation to the Broadstreet
Enterprise
i. BSG Fund and the Broad Street Entities
26. BSG Fund was formed in September 2020 to operate as a private equity fund. In
the fourth quarter of 2020, BSG Fund purchased substantially all of the investment assets of
Broad Street Global Fund SCSp, a Luxembourg entity, which was a predecessor fund to the BSG
Fund.
27. BSG Fund’s offering materials claim that it is divided into a number of Series,
each of which focuses on a separate and distinct investment opportunity.
28. BSG Fund is managed by BSG Management, which has authority to manage BSG
Fund’s activities. Joseph Baldassarra and Steven Baldassarra are the managing members of BSG
Management, and BSG Management acts through the Baldassarras. Throughout the Relevant


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Period, BSG Management has been controlled by the Baldassarras and since June 2022, as
alleged further below, Feingold has also controlled BSG Management.
29. BSG Management is not registered as an investment adviser with the SEC,
although as alleged below it acts as an investment adviser with respect to BSG Fund.
30. In or around June 2022, Feingold formed and became the CEO of BSI. Joseph
Baldassarra is the President of BSI and Steven Baldassarra is the Chief Operating Officer of BSI.
The sales staff that solicits investors for BSG Fund are BSI personnel. BSI owns at least some of
the real estate assets acquired with BSG Fund’s funds. BSI oversees assets in which BSG Fund
has invested.
31. From at least July 2022 until the present, BSI’s publicly-available website
contains information about certain of the Broad Street Entities, and illustrates the related nature
of the Broad Steet Entities and the BSG Fund Series. For example, from approximately July
2022 through approximately March 2024, the following diagram was included on BSI’s website:


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i. BSG Management and BSI Offered and Sold More Than $1 Billion of
Securities.
32. From October 1, 2020 through the present (“Relevant Period”), investors have
deposited more than $1 billion in the bank accounts of BSG Fund, BSG Series CM, and BSG
Management. Of this amount, investors deposited approximately $868 million in the BSG
Fund’s bank accounts, approximately $199 million in BSG CM Series’ bank accounts, and
approximately $9 million in BSG Management’s bank accounts.
33. From the more than $1 billion that investors deposited in the above referenced
bank accounts, approximately $880 million has been transferred to (or directly deposited) in
BSG Management’s bank accounts and extensively commingled. The chart below demonstrates
the flow of investor funds to BSG Management:


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34. During the Relevant Period, BSG Management has continuously solicited money
from, and offered and sold BSG Fund LLC units in a variety of Series to investors.
35. From approximately October 1, 2020 until approximately May 2022, BSG
Management used an internal sales staff to offer and sell BSG Fund LLC units. The internal sales
staff was used to, among other things: (a) solicit investors; (b) send out offering materials; (c)
prepare closing resolutions; and (d) assist with the preparation of account statements.
36. From approximately June 2022, until at least October 31, 2024, BSG
Management and BSI have used an internal sales staff comprised of BSI personnel to offer and
sell BSG Fund LLC units. BSI’s staff is used to, among other things: (a) solicit investors; (b)
send out offering materials; (c) prepare closing resolutions; and (d) assist with the preparation of
account statements.
37. In addition, since at least August 2022, BSG Management has utilized registered
broker-dealers to sell the offering pursuant to placement agreements.
38. As a result of the solicitation efforts undertaken by BSG Management, BSI, and
associated broker-dealers, BSG Management has raised more than $1 billion on behalf of the
BSG Fund from over a thousand passive investors. These investors are located across the United
States, including in this district, and abroad.
39. The BSG Fund LLC units that BSG Management offered and sold to investors are
securities as defined in Section 2(a)(1) of the Securities Act [15 U.S.C. § 77b(a)(1)] and Section
3(a)(10) of the Exchange Act [15 U.S.C. § 78c(a)(10)]. Section 2(a)(l) of the Securities Act and
Section 3(a)(10) of the Exchange Act define “security” to include, among other things,
“investment contracts.” An investment contract exists where a person invests his or her money,


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H. Relief Defendants Received Proceeds or Own or Maintain Assets from
Defendants’ Fraud to Which They Have No Legitimate Claim.
252. As alleged above, Joseph Benjamin is the entity through which Joseph
Baldassarra received approximately $65.7 million in payments from the Broad Street Entities’
bank accounts from at least January 1, 2020 through at least October 31, 2024. Joseph Benjamin
has no legitimate claim to those funds. As a result, those funds should be returned to defrauded
investors and to the BSG Fund.
253. As alleged above, Just A Nice Day is the entity through which Steven Baldassarra
received approximately $53.2 million in payments from the Broad Street Entities’ bank accounts
from at least January 1, 2020 through at least October 31, 2024. Just A Nice Day has no
legitimate claim to those funds. As a result, those funds should be returned to defrauded
investors and to the BSG Fund.
IV. CLAIMS FOR RELIEF
First Claim for Relief
Violations of Sections 17(a)(1) and (3) of the Securities Act
(Against All Defendants)

254. The Commission repeats and realleges Paragraphs 1 through 253 of this
Complaint.
255. Defendants, directly or indirectly, in the offer or sale of securities by the use of
means or instruments of transportation or communication in interstate commerce or by use of the


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mails, acting with the requisite state of mind: (a) employed devices, schemes, or artifices to
defraud and (b) engaged in transactions, practices, or courses of business which operated or
would operate as a fraud or deceit upon the purchaser.
256. By engaging in the conduct described above, Defendants violated, and unless
restrained and enjoined will continue to violate, Sections 17(a)(1) and (3) of the Securities Act
[15 U.S.C. §§ 77q(a)].
Second Claim for Relief
Violation of Section 17(a)(2) of the Securities Act
(Against BSG Management, Joseph Baldassarra, Steven Baldassarra and Feingold)

257. The Commission repeats and realleges Paragraphs 1 through 253 of this
Complaint.
258. BSG Management, Joseph Baldassarra, Steven Baldassarra, and Feingold, directly
or indirectly, in the offer or sale of securities by the use of means or instruments of transportation
or communication in interstate commerce or by use of the mails, acting with the requisite state of
mind obtained money or property by means of untrue statements of a material fact or by omitting
to state a material fact necessary in order to make the statements made, in light of the
circumstances under which they were made, not misleading.
259. By engaging in the conduct described above, BSG Management, Joseph
Baldassarra, Steven Baldassarra, and Feingold violated, and unless restrained and enjoined will
continue to violate, Section 17(a)(2) of the Securities Act [15 U.S.C. §§ 77q(a)].
Third Claim for Relief
Violations of Sections 10(b) of the Exchange Act and Rules 10b-5(a) and (c)
(Against All Defendants)

260. The Commission repeats and realleges Paragraphs 1 through 253 of this
Complaint.


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261. Defendants, directly or indirectly, in connection with the purchase or sale of a
security, and by the use of means or instrumentalities of interstate commerce, of the mails, or of
the facilities of a national securities exchange, knowingly and severely recklessly: employed
devices, schemes, or artifices to defraud and engaged in acts, practices, or courses of business
which operated or would operate as a fraud or deceit upon other persons.
262. By engaging in the conduct described above, Defendants, directly and indirectly,
have violated and unless enjoined, are reasonably likely to continue to violate, Section 10(b) of
the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5(a) and (c) [17 C.F.R. § 240.10b-5(a) and
(c)] thereunder.
Fourth Claim for Relief
Violations of Sections 10(b) of the Exchange Act and Rules 10b-5(b)
(Against BSG Management, Joseph Baldassarra, and Steven Baldassarra)

263. The Commission repeats and realleges Paragraphs 1 through 253 of this
Complaint.
264. Defendants BSG Management, Joseph Baldassarra, and Steven Baldassarra,
directly or indirectly, in connection with the purchase or sale of a security, and by the use of
means or instrumentalities of interstate commerce, of the mails, or of the facilities of a national
securities exchange, knowingly and severely recklessly made untrue statements of a material fact
or omitted to state a material fact necessary in order to make the statements made, in the light of
the circumstances under which they were made, not misleading.
265. By engaging in the conduct described above, BSG Management, Joseph
Baldassarra, and Steven Baldassarra, directly and indirectly, have violated and unless enjoined,
are reasonably likely to continue to violate, Section 10(b) of the Exchange Act [15 U.S.C. §
78j(b)] and Rule 10b-5(b) [17 C.F.R. § 240.10b-5(b)] thereunder.


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Fifth Claim for Relief
Violations of Sections 206(1) and 206(2) of the Advisers Act
(Against BSG Management, Joseph Baldassarra, and Steven Baldassarra)

266. The Commission repeats and realleges Paragraphs 1 through 253 of this
Complaint.
267. Defendants BSG Management, Joseph Baldassarra, and Steven Baldassarra are
investment advisers as defined by Section 202(a)(11) of the Advisers Act [15 U.S.C. § 80b-
2(a)(11)].
268. Defendants BSG Management, Joseph Baldassarra, and Steven Baldassarra, while
acting as investment advisers, directly or indirectly, by use of the mails or means and
instrumentalities of interstate commerce, acting with the requisite state of mind: (a) employed or
are employing devices, schemes or artifices to defraud clients or prospective clients; and (b)
engaged in or are engaging in transactions, practices, or courses of business which operated as a
fraud or deceit upon clients or prospective clients.
269. By engaging in the conduct described above, Defendants violated, and unless
restrained and enjoined, will continue to violate, Sections 206(1) and 206(2) of the Advisers Act
[15 U.S.C. §§ 80b-6(1) and 80b-6(2)].
Sixth Claim for Relief
Control Person Liability for BSG Management’s and BSI’s
Violations of the Exchange Act
(Against Feingold, Joseph Baldassarra, and Steven Baldassarra)
270. The Commission repeats and realleges Paragraphs 1 through 253 of this
Complaint.
271. As alleged above, Defendant BSG Management violated Section 10(b) of the
Exchange Act and Rule 10b-5 thereunder and Defendant BSI violated Section 10(b) of the
Exchange Act and Rules 10b-5(a) and (c) thereunder.


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272. Defendants Feingold, Joseph Baldassarra, and Steven Baldassarra, directly or
indirectly, each controlled Defendants BSG Management and BSI by possessing, directly or
indirectly, the power to direct or cause the direction of the management and policies of
Defendants BSG Management and BSI through the ownership of voting securities, by contract,
or otherwise, which resulted in Defendant’s BSG Management’s and BSI’s primary liability.
273. Defendants Feingold, Joseph Baldassarra, and Steven Baldassarra, directly or
indirectly, each exercised actual control over BSG Fund and BSI, by exercising their power to
control the general affairs of BSG Fund and BSI, and exercised their power to control or
influence the specific corporate policy of BSG Fund and BSI, which resulted in Defendant’s
BSG Management’s and BSI’s primary liability.
274. Defendants Feingold, Joseph Baldassarra, and Steven Baldassarra are each liable
as a control person under Section 20(a) of the Exchange Act [15 U.S.C. § 78t(a)] for BSG Fund’s
and BSI’s violations of the Exchange Act.
275. By engaging in the conduct described above, Defendants Feingold, Joseph
Baldassarra, and Steven Baldassarra, each violated, and unless restrained and enjoined, will
continue to violate, Section 20(a) of the Exchange Act [15 U.S.C. § 78t(a)].
Seventh Claim for Relief
Disgorgement from Relief Defendants – Pursuant to Section 6501 of the National Defense
Authorization Act for Fiscal Year 2021, Pub. L. No. 116-283 and Equitable Principles
(Against All Relief Defendants)

276. The Commission repeats and realleges Paragraphs 1 through 253 of this
Complaint.
277. Each Relief Defendant obtained money, property, or assets that are the proceeds
of, or are traceable to, the proceeds of the fraud and violations of the securities laws by
Defendants.


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278. Each Relief Defendant has no legitimate claim to these illicit proceeds or assets,
having obtained the funds under circumstances in which it is not just, equitable, or conscionable
for it to retain the funds or assets, and therefore each of them has been unjustly enriched.
V. PRAYER FOR RELIEF
WHEREFORE,  the  Commission  respectfully  requests  the  Court  find  the  Defendants
committed the violations alleged, and enter the following relief:
A. Injunctions
Enter  an  injunction,  in  a  form  consistent  with  Rule  65  of  the  Federal  Rules  of  Civil
Procedure,   permanently   restraining   and   enjoining   Defendants   and   their   agents,   servants,
employees, attorneys, and accountants, and those persons in active concert or participation with
him or it, who receive actual notice of the Final Judgment by personal service or otherwise, and
each  of  them,  from  engaging  in  transactions,  acts,  practices,  and  courses  of  business  described
herein, and from engaging in conduct of similar purport and object in violation of Section 17(a) of
Securities Act [15 U.S.C. § 77q(a)]; Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and
Exchange Act Rule 10b-5 [17 C.F.R. § 240.10b-5] thereunder; and Section 20(a) of the Exchange
Act;  and,  as  to  Defendants  BSG  Management,  Joseph  Baldassarra,  and  Steven  Baldassarra,
Sections 206(1) and 206(2) of the Advisers Act [15 U.S.C. §§ 80b-6(1) and 80b-6(2)].
Issue an order permanently enjoining Feingold, Steven Baldassarra, and Joseph
Baldassarra, from directly or indirectly participating in the issuance, purchase, offer, or sale of
any security, provided, however, that such injunction shall not prevent any of them from
purchasing or selling securities for their own personal account.
B. Disgorgement


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Issue an order directing Defendants and Relief Defendants to disgorge all ill-gotten gains
received, directly or indirectly, including prejudgment interest, derived from the acts or courses
of conduct alleged in this Complaint. In addition, issue an order finding that Defendants
Feingold, Joseph Baldassarra, and Steven Baldassarra, jointly and severally liable for
disgorgement ordered against Defendants BSI and BSG Management.
C. Civil Monetary Penalties
Issue an order directing Defendants to pay civil money penalties pursuant to Section
20(d) of the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d) of the Exchange Act [15
U.S.C. § 78u(d)], and, in addition, as to Defendants BSG Management, Joseph Baldassarra, and
Steven Baldassarra, Section 209(e) of the Advisers Act [15 U.S.C. § 80b-9(e)].
D. Further Relief
Grant such other and further relief as may be necessary and appropriate.
E. Retention of Jurisdiction
Issue  an  order  retaining  jurisdiction  over  this  action  and  over  Defendants  in  order  to
implement and carry out the terms of all orders that may be entered, or to entertain any suitable
application or motion by the SEC for additional relief within the jurisdiction of this Court.
DEMAND FOR JURY TRIAL
The SEC hereby demands a trial by jury on any and all issues in this action so triable.
Respectfully submitted,
Dated: January 29, 2025 By: s:/ Christopher E. Martin
Christopher E. Martin, Esq.
S.D. Fla Bar No. A5500747
(303) 844-1106
[email protected]

Terry R. Miller
S.D. Fla. Bar No. A5503312


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(303) 844-1041
[email protected]

Jacqueline M. Moessner
S.D. Fla. Bar No. A5503301
(303) 844-1031
[email protected]
      Attorneys for Plaintiff
UNITED STATES SECURITIES AND
EXCHANGE COMMISSION
1961 Stout Street, 17th Floor
Denver, Colorado 80294
(303) 844-1000

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 

CASE NO. 

SECURITIES AND EXCHANGE COMMISSION, 

Plaintiff, 
v. JURY TRIAL DEMANDED 

DAVID J. FEINGOLD, 
JOSEPH B. BALDASSARRA, 
STEVEN S. BALDASSARRA,  
BROAD STREET GLOBAL MANAGEMENT, LLC, and 
BROAD STREET INC.,  

Defendants, and 

JOSEPHBENJAMIN, INC., and 
JUST A NICE DAY, INC. 

Relief Defendants. 
_________________________________________/  

COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF 

Plaintiff Securities and Exchange Commission (the “SEC”) alleges as follows: 

I. INTRODUCTION

1. The SEC brings this enforcement action to stop an ongoing offering fraud

perpetrated by David J. Feingold, Joseph B. Baldassarra, Steven S. Baldassarra, and the entities 

they control – Broad Street, Inc. (“BSI”) and Broad Street Global Management (“BSG 

Management”). Feingold, the Baldassarras, and their entities used deceptive schemes and 

materially false statements to raise money from investors in Broad Street Global Fund, LLC 

(“BSG Fund” or the “Fund”), a private equity fund that the Defendants used to raise more than 

$1 billion from over a thousand investors. The SEC seeks temporary and preliminary relief, 

1:25-cv-20436

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including an asset freeze and injunctions, as well as the appointment of a receiver, to put a stop 

to Defendants’ misconduct. 

2. BSG Fund is divided into numerous Series. BSG Management, which is the 

investment adviser to the Fund, offered Series in Real Estate Infrastructure, Merchant Cash 

Advances, Custom Home Building, Hotel Projects, and numerous other specialized areas. Each 

of these Series is supposed to present an investor with a unique investment opportunity, with its 

own unique possible profits and risk. 

3.  However, Defendants engaged in a multi-faceted fraud related to BSG Fund. 

First, Defendants fraudulently offered and paid inflated returns to investors in at least two major 

Series, claiming that investments in Merchant Cash Advances – short term and fast funding 

transactions to small business – generated significant profits when in fact they did not. As a 

result, Defendants paid millions of dollars in returns to investors that were not supported by 

actual MCA profits. 

4. Second, the Defendants managed the Fund in a way that was inconsistent with 

what they told investors and that materially increased investors’ risk. The Baldassarras and BSG 

Management told investors that the Fund would follow certain structures and practices to protect 

their investments: that they would keep the assets and liabilities of each Series separate, that 

there would not be commingling of funds or assets between the Series, that there would be no 

cross-liability between Series, and that the Fund would own the investments made with investor 

funds. In fact, funds were commingled and cross-liabilities created, subjecting investors in one 

Series to risks in other Series. Moreover, nearly all investor funds were diverted to accounts and 

assets owned and controlled by BSG Management, the Baldassarras, or BSI. BSG Management 

made almost no investments on behalf of the BSG Fund. 

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5. Third, the Baldassarras and BSG Management made numerous false and 

misleading statements to induce investors to invest with the Fund.  In addition to the 

misstatements noted above, they falsely promised investors that a certain Series – related to 

Qualified Small Business Stock – would generate tax-free returns, when in fact the funds were 

not invested as promised and do not qualify for favorable tax treatment. They made false 

statements about the Fund’s recordkeeping practices and financial statements. And finally, as 

noted above, they misled investors about the profitability of the MCA investments. 

6.  Fourth, Defendants engaged in additional deceptive conduct in their operation of 

the Fund, all of which resulted in fraud on the Fund and its investors. 

7.  In addition, the Baldassarras and BSG Management are investment advisers to 

the BSG Fund, and thus have critical fiduciary obligations to their client, including duties of 

loyalty and care, which impose on them an affirmative duty of utmost good faith, and an 

obligation to provide full and fair disclosure of all material facts. Through the conduct alleged 

below, the Baldassarras and BSG Management fell vastly short of these obligations. 

8.   From the more than $1 billion that Defendants have raised, the Baldassarras 

have transferred (or had investors send money to BSG Management directly) approximately 

$880 million to BSG Management. From these funds, Feingold and the Baldassarras have 

transferred approximately $170 million to the Baldassarras and to entities under the control of 

Feingold or the Baldassarras. 

9. By engaging in the conduct alleged in this complaint, Defendants Feingold, 

Joseph Baldassarra, Steven Baldassarra, BSG Management, and BSI (collectively “Defendants”) 

violated the antifraud provisions of Section 17(a) of the Securities Act of 1933 (“Securities Act”) 

[15 U.S.C. § 77q(a)], and Section 10(b) of the Exchange Act of 1934 (“Exchange Act”) [15 

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U.S.C. § 78j(b)], and Exchange Act Rule 10b-5(a) and (c) thereunder [17 C.F.R. § 240.10b-5(a) 

and (c)]. In addition, Defendants BSG Management and the Baldassarras, violated the antifraud 

provisions of Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)], and Exchange Act Rule 

10b-5(b) thereunder [17 C.F.R. § 240.10b-5(b)]. The Baldassarras and Feingold are also liable as 

control persons over BSG Management and BSI pursuant to Section 20(a) of the Exchange Act 

[15 U.S.C. § 78t(a)]. 

10.  In addition, BSG Funds’ investment advisers, Defendants BSG Management and 

the Baldassarras (collectively “BSG Fund’s Investment Advisers”), breached the fiduciary duties 

they owed to the BSG Fund in violation of the antifraud provisions of Sections 206(1) and 

206(2) of the Advisers Act of 1940 (“Advisers Act”) [15 U.S.C. §§ 80b-6(1) and 80b-6(2)]. 

11. Furthermore, Relief Defendants Josephbenjamin, Inc. (“Joseph Benjamin”), 

owned and controlled by Joseph Baldassarra, and Just A Nice Day, Inc. (“Just a Nice Day”), 

owned and controlled by Steven Baldassarra (collectively, “Relief Defendants”) have each 

received substantial illicit proceeds from the Defendants’ fraud to which they have no legitimate 

claim and under circumstances in which it is not just, equitable, or conscionable for them to 

retain the funds. 

II. PARTIES AND RELATED ENTITIES 

a. Defendants  

12. David J. Feingold, Esq. (“Feingold”), age 58, is a resident of Aventura, Florida. 

Feingold is the Chief Executive Officer (“CEO”) of BSI and a control person over BSI and BSG 

Management. The Baldassarras have delegated the management of many, including the largest, 

business lines funded by BSG Fund, including real estate infrastructure projects and merchant 

cash advance (“MCA portfolios”), to Feingold. Feingold is an attorney licensed in the state of 

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Florida. In 1999, the Commission entered an order against Feingold to cease and desist from 

committing or causing any violations of Section 5 of the Securities Act and Rule 10b-13 of the 

Exchange Act. 

13.  Joseph B. Baldassarra, age 48, is a resident of Simpsonville, South Carolina. He 

is a managing member of BSG Management, the President of BSI, and a control person over BSI 

and BSG Management. His responsibilities include: acting as investment adviser to the BSGF 

Fund, along with Defendants BSG Management and Steven Baldassarra; soliciting investors for 

BSG Fund; and supervising BSI’s internal sales staff who, among other things, solicit investors 

for BSG Fund. Joseph Baldassarra was associated with several registered broker-dealers between 

1998 and 2016. 

14. Steven S. Baldassarra, age 49, is a resident of Simpsonville, South Carolina. He is 

a managing member of BSG Management, the chief operating officer (“COO”) of BSI, and a 

control person over BSI and BSG Management. His responsibilities include: acting as 

investment adviser to the BSG Fund, along with Defendants BSG Management and Joseph 

Baldassarra; and performing back-office functions for BSG Fund, including overseeing BSG 

Fund’s and BSG Management’s bank accounts, and its accounting staff. Steven Baldassarra was 

associated with several registered broker-dealers between 1998 and 2016. 

15. Broad Street Global Management LLC (“BSG Management”) is a South Carolina 

LLC that was formed on or about October 2018. BSG Management is the designated manager of 

BSG Fund. BSG Management is owned and managed by the Baldassarras and is controlled by 

the Baldassarras and Feingold. BSG Management (through the Baldassarras) acts as an 

investment adviser with respect to BSG Fund. BSG Management has received approximately $9 

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million directly from investors and more than $871 million from the bank accounts of BSG Fund 

and BSG Series CM, LLC’s (“BSG CM Series”) bank accounts.   

16. Broad Street Inc. (“BSI”) is a Delaware corporation that was formed on or about 

June 2022. BSI’s voting shares are owned in equal parts by the Baldassarras and Feingold and 

unanimity by all three is required for shareholder decisions. Since approximately June 2022 

through the present, Feingold has been the CEO, Joseph Baldassarra has been the President, and 

Steven Baldassarra has been the COO, of BSI. Feingold and the Baldassarras control BSI. BSI 

has received more than $200,000, an interest in a registered broker-dealer, and ownership over 

certain real estate assets.  

A. Relief Defendants 

17. Josephbenjamin, Inc. (“Joseph Benjamin”) is a South Carolina corporation owned 

and controlled by Joseph Baldassarra. Through Joseph Benjamin, Joseph Baldassarra received 

more than $65 million of illicit proceeds. 

18. Just a Nice Day, Inc. (“Just A Nice Day”) is a South Carolina corporation owned 

and controlled by Steven Baldassarra. Through Just a Nice Day, Steven Baldassarra received 

more than $50 million of illicit proceeds. 

B. Related Entities 

19. Broad Street Global Fund LLC (“BSG Fund”) is a multi-Series Delaware LLC 

that was formed on or about September 14, 2020. BSG Fund is a private equity fund. BSG Fund 

has no managing board and thus cannot act for itself. Instead, BSG Fund’s operating agreement 

vests all authority to act for BSG Fund in its manager BSG Management (or its agents). BSG 

Fund has directly received more than $868 million from investors in exchange for limited 

partnership interests in BSG Fund.  

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20. Broadstreet Global Holdings, LLC (“BSG Holdings”) is a South Carolina LLC. 

BSG Holdings is owned and managed by the Baldassarras. BSG Holdings receives funds to pay 

the expenses for BSG Fund, BSG Management, and BSI. BSG Holdings has received more than 

$134.5 million from BSG Management. 

21. BSG Series CM, LLC (“BSG Series CM”) is a South Carolina LLC that is owned 

and managed by the Baldassarras. BSG Series CM is related to one or more crypto asset mining 

Series in the BSG Fund that is offered and sold by BSG Management and BSI. Its bank accounts 

have received approximately $199 million from investors.  

22. BSG Management, BSI, BSG Fund, BSG Holdings, and BSG Series CM are 

referred to herein as the “Broad Street Entities.” 

III. JURISDICTION AND VENUE 

23. This Court has jurisdiction over this action pursuant to Sections 20(b), 20(d), and 

22(a) of the Securities Act [15 U.S.C. §§ 77t(b), 77t(d), and 77v(a)]; Sections 21(d), 21(e), and 

27(a) of the Exchange Act [15 U.S.C. §§ 78u(d), 78u(e) and 78aa(a)]; and Sections 209(d) and 

214(a) of the Advisers Act [15 U.S.C. §§ 80b-9(d) and 80b-14(a)].  

24. Defendants, directly or indirectly, singly or in concert with others, made use of 

the means or instruments of transportation or communication in interstate commerce, the means 

and instrumentalities of interstate commerce, or of the mails, in connection with the acts, 

practices, and courses of business set forth in this Complaint. 

25. This Court has personal jurisdiction over the Defendants and Relief Defendants 

and venue is proper in the Southern District of Florida pursuant to Section 20(b), 20(d)(1), and 

22(a) of the Securities Act [15 U.S.C. §§ 77t(b), 77t(d)(1), and 77v(a)]; Section 21(d) and 27 of 

the Exchange Act [15 U.S.C. §§ 78u(d) and 78aa]; Sections 209(d) and 214(a) of the Advisers 

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Act [15 U.S.C. §§ 80b-9(d) and 80b-14(a)]; and 28 U.S.C. § 1391(b) because, among other 

reasons: (a) Defendant Feingold, CEO of Defendant BSI and an undisclosed control person of 

Defendant BSG Management has resided in this district since at least June 2022; (b) Defendant 

BSI has additional staff that work on behalf of the Broad Street Entities that reside in this district, 

some of whom are also shareholders of Defendant BSI; (c) an accounting firm used by 

Defendants is located in this district; (d) the home builder associated with BSG Fund’s custom 

home sub-Series whose “nerve center” is located in this district has filed for bankruptcy in this 

District; (e) more than 70 investors that have invested in the BSG Fund reside in this district; (f) 

a registered broker used to solicit investors and is partially owned by Defendant BSI is located in 

this district; and (g) many of the acts, practices, transactions, and courses of business alleged in 

this Complaint occurred within this district. 

IV. FACTUAL ALLEGATIONS      

A. BSG Fund’s Formation, Operation, and Relation to the Broadstreet 
Enterprise 

i. BSG Fund and the Broad Street Entities  

26. BSG Fund was formed in September 2020 to operate as a private equity fund. In 

the fourth quarter of 2020, BSG Fund purchased substantially all of the investment assets of 

Broad Street Global Fund SCSp, a Luxembourg entity, which was a predecessor fund to the BSG 

Fund. 

27. BSG Fund’s offering materials claim that it is divided into a number of Series, 

each of which focuses on a separate and distinct investment opportunity. 

28. BSG Fund is managed by BSG Management, which has authority to manage BSG 

Fund’s activities. Joseph Baldassarra and Steven Baldassarra are the managing members of BSG 

Management, and BSG Management acts through the Baldassarras. Throughout the Relevant 

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Period, BSG Management has been controlled by the Baldassarras and since June 2022, as 

alleged further below, Feingold has also controlled BSG Management. 

29. BSG Management is not registered as an investment adviser with the SEC, 

although as alleged below it acts as an investment adviser with respect to BSG Fund.  

30. In or around June 2022, Feingold formed and became the CEO of BSI. Joseph 

Baldassarra is the President of BSI and Steven Baldassarra is the Chief Operating Officer of BSI. 

The sales staff that solicits investors for BSG Fund are BSI personnel. BSI owns at least some of 

the real estate assets acquired with BSG Fund’s funds. BSI oversees assets in which BSG Fund 

has invested.  

31. From at least July 2022 until the present, BSI’s publicly-available website 

contains information about certain of the Broad Street Entities, and illustrates the related nature 

of the Broad Steet Entities and the BSG Fund Series. For example, from approximately July 

2022 through approximately March 2024, the following diagram was included on BSI’s website: 

 

 

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i. BSG Management and BSI Offered and Sold More Than $1 Billion of 
Securities. 

32. From October 1, 2020 through the present (“Relevant Period”), investors have 

deposited more than $1 billion in the bank accounts of BSG Fund, BSG Series CM, and BSG 

Management. Of this amount, investors deposited approximately $868 million in the BSG 

Fund’s bank accounts, approximately $199 million in BSG CM Series’ bank accounts, and 

approximately $9 million in BSG Management’s bank accounts.  

33. From the more than $1 billion that investors deposited in the above referenced 

bank accounts, approximately $880 million has been transferred to (or directly deposited) in 

BSG Management’s bank accounts and extensively commingled. The chart below demonstrates 

the flow of investor funds to BSG Management: 

 

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34. During the Relevant Period, BSG Management has continuously solicited money 

from, and offered and sold BSG Fund LLC units in a variety of Series to investors. 

35. From approximately October 1, 2020 until approximately May 2022, BSG 

Management used an internal sales staff to offer and sell BSG Fund LLC units. The internal sales 

staff was used to, among other things: (a) solicit investors; (b) send out offering materials; (c) 

prepare closing resolutions; and (d) assist with the preparation of account statements. 

36. From approximately June 2022, until at least October 31, 2024, BSG 

Management and BSI have used an internal sales staff comprised of BSI personnel to offer and 

sell BSG Fund LLC units. BSI’s staff is used to, among other things: (a) solicit investors; (b) 

send out offering materials; (c) prepare closing resolutions; and (d) assist with the preparation of 

account statements. 

37. In addition, since at least August 2022, BSG Management has utilized registered 

broker-dealers to sell the offering pursuant to placement agreements. 

38. As a result of the solicitation efforts undertaken by BSG Management, BSI, and 

associated broker-dealers, BSG Management has raised more than $1 billion on behalf of the 

BSG Fund from over a thousand passive investors. These investors are located across the United 

States, including in this district, and abroad. 

39. The BSG Fund LLC units that BSG Management offered and sold to investors are 

securities as defined in Section 2(a)(1) of the Securities Act [15 U.S.C. § 77b(a)(1)] and Section 

3(a)(10) of the Exchange Act [15 U.S.C. § 78c(a)(10)]. Section 2(a)(l) of the Securities Act and 

Section 3(a)(10) of the Exchange Act define “security” to include, among other things, 

“investment contracts.” An investment contract exists where a person invests his or her money, 

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H. Relief Defendants Received Proceeds or Own or Maintain Assets from 
Defendants’ Fraud to Which They Have No Legitimate Claim. 

252. As alleged above, Joseph Benjamin is the entity through which Joseph 

Baldassarra received approximately $65.7 million in payments from the Broad Street Entities’ 

bank accounts from at least January 1, 2020 through at least October 31, 2024. Joseph Benjamin 

has no legitimate claim to those funds. As a result, those funds should be returned to defrauded 

investors and to the BSG Fund. 

253. As alleged above, Just A Nice Day is the entity through which Steven Baldassarra 

received approximately $53.2 million in payments from the Broad Street Entities’ bank accounts 

from at least January 1, 2020 through at least October 31, 2024. Just A Nice Day has no 

legitimate claim to those funds. As a result, those funds should be returned to defrauded 

investors and to the BSG Fund. 

IV. CLAIMS FOR RELIEF 

First Claim for Relief 
Violations of Sections 17(a)(1) and (3) of the Securities Act 

(Against All Defendants) 
 

254. The Commission repeats and realleges Paragraphs 1 through 253 of this 

Complaint. 

255. Defendants, directly or indirectly, in the offer or sale of securities by the use of 

means or instruments of transportation or communication in interstate commerce or by use of the 

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mails, acting with the requisite state of mind: (a) employed devices, schemes, or artifices to 

defraud and (b) engaged in transactions, practices, or courses of business which operated or 

would operate as a fraud or deceit upon the purchaser. 

256. By engaging in the conduct described above, Defendants violated, and unless 

restrained and enjoined will continue to violate, Sections 17(a)(1) and (3) of the Securities Act 

[15 U.S.C. §§ 77q(a)]. 

Second Claim for Relief 
Violation of Section 17(a)(2) of the Securities Act 

(Against BSG Management, Joseph Baldassarra, Steven Baldassarra and Feingold) 
 

257. The Commission repeats and realleges Paragraphs 1 through 253 of this 

Complaint. 

258. BSG Management, Joseph Baldassarra, Steven Baldassarra, and Feingold, directly 

or indirectly, in the offer or sale of securities by the use of means or instruments of transportation 

or communication in interstate commerce or by use of the mails, acting with the requisite state of 

mind obtained money or property by means of untrue statements of a material fact or by omitting 

to state a material fact necessary in order to make the statements made, in light of the 

circumstances under which they were made, not misleading. 

259. By engaging in the conduct described above, BSG Management, Joseph 

Baldassarra, Steven Baldassarra, and Feingold violated, and unless restrained and enjoined will 

continue to violate, Section 17(a)(2) of the Securities Act [15 U.S.C. §§ 77q(a)]. 

Third Claim for Relief 
Violations of Sections 10(b) of the Exchange Act and Rules 10b-5(a) and (c) 

(Against All Defendants) 
 

260. The Commission repeats and realleges Paragraphs 1 through 253 of this 

Complaint. 

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261. Defendants, directly or indirectly, in connection with the purchase or sale of a 

security, and by the use of means or instrumentalities of interstate commerce, of the mails, or of 

the facilities of a national securities exchange, knowingly and severely recklessly: employed 

devices, schemes, or artifices to defraud and engaged in acts, practices, or courses of business 

which operated or would operate as a fraud or deceit upon other persons. 

262. By engaging in the conduct described above, Defendants, directly and indirectly, 

have violated and unless enjoined, are reasonably likely to continue to violate, Section 10(b) of 

the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5(a) and (c) [17 C.F.R. § 240.10b-5(a) and 

(c)] thereunder. 

Fourth Claim for Relief 
Violations of Sections 10(b) of the Exchange Act and Rules 10b-5(b) 

(Against BSG Management, Joseph Baldassarra, and Steven Baldassarra) 
 

263. The Commission repeats and realleges Paragraphs 1 through 253 of this 

Complaint. 

264. Defendants BSG Management, Joseph Baldassarra, and Steven Baldassarra, 

directly or indirectly, in connection with the purchase or sale of a security, and by the use of 

means or instrumentalities of interstate commerce, of the mails, or of the facilities of a national 

securities exchange, knowingly and severely recklessly made untrue statements of a material fact 

or omitted to state a material fact necessary in order to make the statements made, in the light of 

the circumstances under which they were made, not misleading. 

265. By engaging in the conduct described above, BSG Management, Joseph 

Baldassarra, and Steven Baldassarra, directly and indirectly, have violated and unless enjoined, 

are reasonably likely to continue to violate, Section 10(b) of the Exchange Act [15 U.S.C. § 

78j(b)] and Rule 10b-5(b) [17 C.F.R. § 240.10b-5(b)] thereunder. 

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Fifth Claim for Relief 
Violations of Sections 206(1) and 206(2) of the Advisers Act 

(Against BSG Management, Joseph Baldassarra, and Steven Baldassarra) 
 
266. The Commission repeats and realleges Paragraphs 1 through 253 of this 

Complaint. 

267. Defendants BSG Management, Joseph Baldassarra, and Steven Baldassarra are 

investment advisers as defined by Section 202(a)(11) of the Advisers Act [15 U.S.C. § 80b-

2(a)(11)]. 

268. Defendants BSG Management, Joseph Baldassarra, and Steven Baldassarra, while 

acting as investment advisers, directly or indirectly, by use of the mails or means and 

instrumentalities of interstate commerce, acting with the requisite state of mind: (a) employed or 

are employing devices, schemes or artifices to defraud clients or prospective clients; and (b) 

engaged in or are engaging in transactions, practices, or courses of business which operated as a 

fraud or deceit upon clients or prospective clients. 

269. By engaging in the conduct described above, Defendants violated, and unless 

restrained and enjoined, will continue to violate, Sections 206(1) and 206(2) of the Advisers Act 

[15 U.S.C. §§ 80b-6(1) and 80b-6(2)]. 

Sixth Claim for Relief 
Control Person Liability for BSG Management’s and BSI’s 

Violations of the Exchange Act 
(Against Feingold, Joseph Baldassarra, and Steven Baldassarra) 

270. The Commission repeats and realleges Paragraphs 1 through 253 of this 

Complaint. 

271. As alleged above, Defendant BSG Management violated Section 10(b) of the 

Exchange Act and Rule 10b-5 thereunder and Defendant BSI violated Section 10(b) of the 

Exchange Act and Rules 10b-5(a) and (c) thereunder. 

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272. Defendants Feingold, Joseph Baldassarra, and Steven Baldassarra, directly or 

indirectly, each controlled Defendants BSG Management and BSI by possessing, directly or 

indirectly, the power to direct or cause the direction of the management and policies of 

Defendants BSG Management and BSI through the ownership of voting securities, by contract, 

or otherwise, which resulted in Defendant’s BSG Management’s and BSI’s primary liability. 

273. Defendants Feingold, Joseph Baldassarra, and Steven Baldassarra, directly or 

indirectly, each exercised actual control over BSG Fund and BSI, by exercising their power to 

control the general affairs of BSG Fund and BSI, and exercised their power to control or 

influence the specific corporate policy of BSG Fund and BSI, which resulted in Defendant’s 

BSG Management’s and BSI’s primary liability. 

274. Defendants Feingold, Joseph Baldassarra, and Steven Baldassarra are each liable 

as a control person under Section 20(a) of the Exchange Act [15 U.S.C. § 78t(a)] for BSG Fund’s 

and BSI’s violations of the Exchange Act. 

275. By engaging in the conduct described above, Defendants Feingold, Joseph 

Baldassarra, and Steven Baldassarra, each violated, and unless restrained and enjoined, will 

continue to violate, Section 20(a) of the Exchange Act [15 U.S.C. § 78t(a)]. 

Seventh Claim for Relief 
Disgorgement from Relief Defendants – Pursuant to Section 6501 of the National Defense 

Authorization Act for Fiscal Year 2021, Pub. L. No. 116-283 and Equitable Principles 
(Against All Relief Defendants) 

 
276. The Commission repeats and realleges Paragraphs 1 through 253 of this 

Complaint. 

277. Each Relief Defendant obtained money, property, or assets that are the proceeds 

of, or are traceable to, the proceeds of the fraud and violations of the securities laws by 

Defendants. 

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278. Each Relief Defendant has no legitimate claim to these illicit proceeds or assets, 

having obtained the funds under circumstances in which it is not just, equitable, or conscionable 

for it to retain the funds or assets, and therefore each of them has been unjustly enriched. 

V. PRAYER FOR RELIEF 

WHEREFORE, the Commission respectfully requests the Court find the Defendants 

committed the violations alleged, and enter the following relief: 

A. Injunctions 

Enter an injunction, in a form consistent with Rule 65 of the Federal Rules of Civil 

Procedure, permanently restraining and enjoining Defendants and their agents, servants, 

employees, attorneys, and accountants, and those persons in active concert or participation with 

him or it, who receive actual notice of the Final Judgment by personal service or otherwise, and 

each of them, from engaging in transactions, acts, practices, and courses of business described 

herein, and from engaging in conduct of similar purport and object in violation of Section 17(a) of 

Securities Act [15 U.S.C. § 77q(a)]; Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and 

Exchange Act Rule 10b-5 [17 C.F.R. § 240.10b-5] thereunder; and Section 20(a) of the Exchange 

Act; and, as to Defendants BSG Management, Joseph Baldassarra, and Steven Baldassarra, 

Sections 206(1) and 206(2) of the Advisers Act [15 U.S.C. §§ 80b-6(1) and 80b-6(2)]. 

Issue an order permanently enjoining Feingold, Steven Baldassarra, and Joseph 

Baldassarra, from directly or indirectly participating in the issuance, purchase, offer, or sale of 

any security, provided, however, that such injunction shall not prevent any of them from 

purchasing or selling securities for their own personal account. 

B. Disgorgement  

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Issue an order directing Defendants and Relief Defendants to disgorge all ill-gotten gains 

received, directly or indirectly, including prejudgment interest, derived from the acts or courses 

of conduct alleged in this Complaint. In addition, issue an order finding that Defendants 

Feingold, Joseph Baldassarra, and Steven Baldassarra, jointly and severally liable for 

disgorgement ordered against Defendants BSI and BSG Management. 

C. Civil Monetary Penalties 

Issue an order directing Defendants to pay civil money penalties pursuant to Section 

20(d) of the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d) of the Exchange Act [15 

U.S.C. § 78u(d)], and, in addition, as to Defendants BSG Management, Joseph Baldassarra, and 

Steven Baldassarra, Section 209(e) of the Advisers Act [15 U.S.C. § 80b-9(e)]. 

D. Further Relief 

Grant such other and further relief as may be necessary and appropriate. 

E. Retention of Jurisdiction 

Issue an order retaining jurisdiction over this action and over Defendants in order to 

implement and carry out the terms of all orders that may be entered, or to entertain any suitable 

application or motion by the SEC for additional relief within the jurisdiction of this Court. 

DEMAND FOR JURY TRIAL 

The SEC hereby demands a trial by jury on any and all issues in this action so triable. 

Respectfully submitted,  

Dated: January 29, 2025 By: s:/ Christopher E. Martin 
Christopher E. Martin, Esq. 
S.D. Fla Bar No. A5500747 
(303) 844-1106 
[email protected] 

 
Terry R. Miller 
S.D. Fla. Bar No. A5503312 

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(303) 844-1041 
[email protected] 
 
Jacqueline M. Moessner 
S.D. Fla. Bar No. A5503301 
(303) 844-1031 
[email protected] 

      Attorneys for Plaintiff 
UNITED STATES SECURITIES AND 
EXCHANGE COMMISSION 
1961 Stout Street, 17th Floor 
Denver, Colorado 80294 
(303) 844-1000 

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