If anyone is following this, the firm offering this "investment" Woodbridge Wealth has received two SEC similar demands this year: "Securities and Exchange Commission v. 235 Limited Liability Companies, No. 1:17-mc-23986-PCH (S.D. Fla., filed October 31, 2017)
SEC Seeks Order Against 235 Entities Affiliated with Woodbridge Group of Companies, LLC to Produce Documents to SEC
The Securities and Exchange Commission has filed a subpoena enforcement action against 235 limited liability companies (the "LLCs") based in Delaware and Colorado seeking an order requiring the production of documents.
According to the SEC's application and supporting papers, filed in federal court in Miami:
The SEC is investigating whether Woodbridge or others have violated, or are violating, the antifraud, broker-dealer and securities registration provisions of the federal securities laws in connection with Woodbridge's receipt of over $1 billion of investor funds from thousands of investors nationwide." https://www.sec.gov/litigation/litrelea ... r23977.htm
They have been given Cease and desist orders from a number of States: including MA, TX, AZ.
The person selling this, mentioned by the OP, looks like an insurance agents http://www.fftaxgroup.us/services/
These sound safe but they are not First Positions: they are 2nd Trust Deed hard money loans. They will pay until the housing market tanks and the borrowers default.
No FINRA broker would sell this due to this: " April 2016, Frank John Capuano (Capuano), a registered representative, settled a complaint with the Financial Industry Regulatory Authority (FINRA), which alleged he participated in several private securities transactions, including the sale of Woodbridge Mortgage Investment Funds notes, without notice to his firm" and "Between December 2014 and March 2015, after learning of the Woodbridge Funds investment opportunity, Capuano offered and sold approximately $1.1 million in Woodbridge notes to nine of his RAI customers, all of whom were his close friends and family. In addition, Capuano purchased $55,000 of Woodbridge notes for himself and his wife in February 2015. Capuano received over $34,000 in commissions in connection with these transactions"
These Sch D offerings that can only be sold an accredited investor: "defined as a person must demonstrate an annual income of $200,000, or $300,000 for joint income, for the last two years with expectation of earning the same or higher income. An individual must have earned income above the thresholds either alone or with a spouse over the last three years. The income test cannot be satisfied by showing one year of an individual's income and the next two years of joint income with a spouse. The exception to this rule is when a person is married within the period of conducting a test. A person is also considered an accredited investor if he has a net worth exceeding $1 million, either individually or jointly with his spouse. The SEC also considers a person to be an accredited investor if he is a general partner, executive officer, director or a related combination thereof for the issuer of unregistered securities."
I am not sure the OP's friend meets these. And I am not sure the Insurance Agent selling these cares.
Finally if anyone has made this far, the SEC information for these Woodbridge Mortgage Investment Funds, Item 15, states ZERO commissions or finders fees. Then how are they paying these Insurance agents? That is a serious question.