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Commerce Department takes action and fines investment advisor operating a Ponzi-scheme targeting elderly investors

July 23, 2014

For Immediate Release:

SAINT PAUL, MN – The Minnesota Department of Commerce ordered Mark Holt, a licensed investment advisor, insurance agent, and attorney, to stop engaging in securities related activity and to pay a $300,000 civil penalty for defrauding multiple investors, many of whom are senior citizens, as part of a Ponzi scheme. The findings of fact issued by the Department allege that Holt misled his clients, usually retirees and the elderly who indicated that they specifically invested their money with him due to his standing as a licensed attorney. 

“Elder financial abuse and crimes are unfortunately on the rise due to the growing number of retirees and the amount of wealth held by seniors. Commerce will take all steps to protect investors and seniors from predators who steal their nest eggs,” said Commerce Commissioner Mike Rothman. “I urge all investors, from the young to young-at-heart, to thoroughly check out individuals and firms prior to entrusting them with your funds.  Look online or call the Commerce Department for help.”

The Department's securities investigators uncovered a scheme orchestrated by Holt who leveraged his position of trust and created a group of sham entities with similar names to funnel investor funds for personal use.  Holt was employed from 2007 to 2013 by Harbour Investments, Inc. a broker dealer firm in Madison, WI.  Using his reputable employment as a cover, Holt created a number of entities using “Harbor” in the title: Harbor Group, Inc., Harbor Financial Group, The Harbor Retirement Group, Harbor Trust Services, The Harbor Group, LLC, and the Harbor Education Institute.  

Holt allegedly took the retirement accounts, IRAs, inheritance, and other funds from his clients and instead of investing the money, he deposited it into one of his sham “Harbor” companies. The Department uncovered instances where Holt allegedly used investor funds for himself: for travel across the country, $13,780 for a White Bear Lake Yacht Club membership, $13,000 for high-end restaurants, thousands of dollars spent on exotic dancers, horse boarding, and $15,000 on a retainer for a criminal defense attorney. 

Many of Holt’s victims were unaware that their funds had been misappropriated and spent because investors initially received monthly checks and statements from Holt, manufactured to show earnings on their investments.  Although the record review is ongoing, the Department estimates the total of misappropriated funds to exceed $2 million.

Mark Holt had a previous run-in with the Commerce Department in 2006 for allegedly selling unsuitable annuities and improperly handling annuity applications and forms.  At that time, the Department put Holt’s license under review, which resulted in Holt being discharged by his employer.  After that, he started working at Harbour Investments.  Investors were allegedly told by Holt that he had left his previous job voluntarily and did not disclose any misconduct.  Holt had been licensed to sell securities and as an insurance producer starting in 1998.  Due to his lengthy career in the financial services industry, many of his investor clients were referrals from previous clients. 

As an important tip to protect investors, the Commerce Department recommends that in addition to word-of-mouth recommendations, prior to choosing an investment advisor or a broker dealer, Minnesota investors can check to make sure the individuals or companies are licensed to do business  in Minnesota and are in compliance with state and federal laws. 

Holt also was licensed as an insurance producer in Minnesota, and due to this investigation, Commerce has revoked his insurance license as well.  The Commerce Department again recommends that Minnesota consumers who are looking for an insurance agent or broker use the Department's Look-Up Tool to ensure that the person or company is licensed to sell insurance in Minnesota.  If the person or company is not licensed in our state, it is a red flag to make sure you do not become scammed.

Commerce is here to help

The Commerce Department is here if you have questions about securities, or believe you have been the victim of a scam or fraud.  Report the fraud, so that others do not fall victim.  If you think you have been a victim, contact the Department's Consumer Response Team at 651-539-1600 or (800) 657-3602.

Complaints can also be sent by email to or by mail to Minnesota Department of Commerce, 85 7th Place East, Suite 500, Saint Paul, MN 55101.