SEC v. Farha, et al.
Case No. 12-cv-00047-SDM-MAP (M.D. Fla.)

On January 9, 2012, the Commission filed a complaint against Todd Farha (“Farha”), Paul Behrens (“Behrens”), and Thaddeus Bereday (“Bereday”) (collectively, the “Defendants’). The complaint alleged that, from 2003 to 2007, the Defendants violated federal securities laws by devising and carrying out a fraudulent scheme that deceived the Florida Agency for Health Care Administration and the Florida Healthy Kids Corporation by improperly retaining over $40 million in health care premiums the company was statutorily and contractually obligated to spend on certain health care services or reimburse to the state agencies. See Complaint.

Farha and Behrens were ordered to pay a total of $17,000,000.00 in disgorgement and penalties. See Farha’s Final Judgment and Behrens’ Final Judgment.

Farha and Behrens have paid a total of $17,000,000.00 (“Distribution Fund”) for distribution to harmed investors.

On May 1, 2018, the Court ordered Bereday to pay $3,500,000.00 in disgorgement and a $1,000,000.00 civil penalty. See the Court's Order.

For more information, please contact the Commission:

Office of Distributions