Instead, new investor funds were used to pay earlier investors, while Frost allegedly diverted millions for personal luxuries, rare coins, family vacations, and political donations. The SEC is seeking emergency relief, including asset freezes and the appointment of a receiver. As of late May 2025, the firm held just $2.67 million despite raising $140 million, exposing the scheme’s collapse. This case underscores the SEC’s crackdown on affinity-based frauds that exploit trusted networks and retail investors.