Behind the Yield

The Emerson Files, Part 3 of 4

By Charles Urquhart, CFA · April 24, 2026

Part 3 of 4

The Reps

The individuals who sold these products. The elderly retirees who bought them. The complaints. And the firm that seemingly never tires of hiring these individuals.

By Charles Urquhart, CFA

April 2026

A quick reminder of how we got here.

Earlier this year, I came across the HPS Corporate Lending Fund, a $15 billion entity who is a BDC (Business Development Company) and who is under the BlackRock umbrella. More importantly, though, it offered a share class, Class F, which had raised $5.9 billion. Furthermore, it was only available to those who purchased through its “Founding Distributor.” There was no name for this entity, nor were there any CRD numbers associated with this “Founding Distributor.” Every other BDC company that I observed had named their distribution partners. The HPS Lending Fund did not. Their filings, however, did lead me to an entity called Emerson Equity LLC of San Mateo, California.

In Part 1 of this article, I revealed to you what I found about this company on BrokerCheck. In Part 2 of this article, I discussed the products that they sold to these elderly investors, how these products all eventually failed, and the enormous commissions that their representatives were paid for these sales.

In Part 3 of this article, I want to share with you the representatives who sold these products to these elderly individuals.

I will begin with a name that you know from Part 2 of this article.

Tony Barouti is the registered representative for whom the SEC issued an enforcement order against the firm Emerson Equity in August of 2025. According to the report on Barouti on BrokerCheck, he has 57 customer disputes that have occurred in the past and 11 pending disputes. Thus, 68 customer disputes by one registered representative for one firm.

But Barouti is not the only individual who sold these products at Emerson Equity. He is, however, the most visible.

The other representative that I want to discuss is Shirley Wong.

Wong is the registered representative for Emerson Equity. She is an individual who came over from a firm called NI Advisors in April of 2024. NI Advisors was one of the 140 firms that Emerson Equity recruited to sell these GWG L Bonds.

Wong has 16 customer disputes on her BrokerCheck report. These cases have involved issues between Wong and her customers regarding breach of contract, breach of fiduciary duty, negligence, Reg BI violations, and the California financial elder abuse statute.

One of these cases revealed that Wong approached a couple in San Francisco who have $200,000 in retirement investments. All of their investments were in GWG L Bonds. According to the case report, Wong told these two individuals that the bonds would return interest to the investors and that their principal would be returned to them. Furthermore, the bonds would be able to be redeemed on the secondary market. None of this was true of the L Bonds. They were unrated, illiquid, and had no secondary market.

When Wong moved from NI Advisors to Emerson Equity, she was listed as having a “Restricted Approval” registration with the state of California for both firms where she used to work. She brought all of these complaints over with her to her new firm at Emerson Equity.

She was not the only representative from these other firms to join Emerson Equity.

Peter Po, another registered representative who used to work for NI Advisors, also moved to work for Emerson Equity in 2024. According to published case descriptions, Po placed the entirety of the liquidity of an investor who did not speak English into the GWG L Bonds. According to BrokerCheck, there are pending complaints against Po as recently as December of 2025.

The president of NI Advisors, Sui-hock Goy, was previously censured by FINRA for failing to supervise the activities of the company representatives. The firm had $60,000 in assets. It had 16 employees in total for the firm, only four of whom were registered with FINRA. Furthermore, representatives who used to work for this firm also had complaints against them related to the sales of the GWG L Bonds.

Thus, the firm that built the sales network for the product that eventually failed and collapsed sent its representatives with the complaints to the firm that absorbed the product.

Robert Scott Smith used to work for Concorde Investment Services. His former firm was the company where he was responsible for selling GPB Capital, which later revealed fraud against the investors who purchased GPB Capital’s alternative investments.

Smith has 16 customer disputes listed on his BrokerCheck report for the GPB Capital investments that he sold. Furthermore, he is also fighting a pending arbitration seeking between $1 million and $2.3 million in funds from GPB Capital investors. Additionally, a pending complaint was filed in October of 2025 in the State of Oregon against Smith for fraud, misrepresentation, and violations of state and federal securities laws.

Smith used to operate under the firm Concorde Investment Services. His current firm is Peregrine Private Capital in Newberg, Oregon. According to case descriptions, Smith recommended a series of illiquid alternative investments to his customers for GPB Capital, which caused the financial instability of his clients and disrupted their retirement plans for those periods of time.

According to the attorneys that represent these clients, Smith’s clients who suffered losses in GPB Capital have now also suffered losses in the Inspired Healthcare Capital Trusts that he recommended through Emerson Equity. The same representative, now at his third firm, selling a different illiquid alternative investment product to a different set of retirees, with the same outcome.

Gabriel Candea operates out of Irvine under the company name Beacon Investment Realty. He has been with Emerson Equity since 2022. According to his BrokerCheck report, a pending complaint has been filed against him in November of 2025 for recommending unsuitable investments in real estate, making misleading recommendations to his clients, violating Regulation Best Interest, and making misrepresentations and omissions of material facts to his clients. The value of the clients’ investments that he lost is $1,083,919.

Alexander Staverosky is also with Emerson Equity and under investigation for a pending complaint with his clients regarding recommending unsuitable real estate securities to his clients.

Phillip Falk is a Senior Vice President at 1031 DST at Emerson Equity. His career began in 1984 in the real estate investment industry. According to his BrokerCheck report, he has a pending customer dispute filed against him in November of 2025.

Christopher Rogers has been with Emerson since 2022 and has a pending complaint against him for making misrepresentations to his clients and violating Regulation Best Interest.

Bruce Beetz has been with Emerson since 2019. According to his BrokerCheck report, he has 7 customer disputes with his clients, including a pending complaint against him in December of 2025 for recommending investments to his clients that were unsuitable for those individuals; the value of those investments that he lost by 2025 is $1,862,532.

Brian Nelson began working for Emerson in 2013. His disputes with his clients involve violations of federal and California securities laws, the California financial elder abuse statute, fraud, and breach of fiduciary duty for investments he made for his clients between 2014 and 2020.

Fred Chen has been with Emerson since 2020. He has at least four disclosable events between his clients and himself, including a pending complaint in December of 2024 for violations of Regulation Best Interest.

Bradley Davidson began working with Emerson in 2024. According to a published pending complaint in January of 2026, he violated federal and California securities laws, committed fraud, and breached his fiduciary duty to his clients.

William Sneckner began to work with Emerson in 2020. According to a pending dispute with his clients filed in January of 2026, he violated Regulation Best Interest for an investment that he placed for his clients in July of 2024.

Andrew Roberson began to work with Emerson in 2025. According to a pending complaint filed against him in January of 2026, he recommended an unapproved private investment to the clients of his office at Emerson, made misrepresentations regarding the investment, and received inadequate supervision from his firm. The value of the investment that his clients lost is $570,000.

Wen Che began to work with Emerson in 2019. According to a pending complaint filed against him in February of 2026, he made negligent recommendations of investments to his clients, misrepresented the extent of the returns that his clients would receive, violated his fiduciary duties to his clients, and violated the California Blue Sky law.

That is not a complete list of the representatives who sold these products at Emerson Equity. These are the individuals that I was able to find via their BrokerCheck reports and published case descriptions of the attorneys involved in these pending legal complaints.

But the patterns among these individuals are clear.

All of them are alleged to have recommended to their clients investments that were unsuitable for those clients, committed a breach of their fiduciary duties to their clients, committed Regulation Best Interest violations, committed acts of negligence, made misrepresentations to their clients of the extent of the returns that they would gain from these investments, failed to provide adequate supervision of the clients of their firms, and committed acts of elder financial abuse of their clients’ funds.

Their products all failed. Their firms all failed. But the complaints against them remained the same.

When the firm GWG failed in 2022, several of the wholesalers that were associated with the firm and who had pitched the L Bonds to the various regional firms within the United States left the firm. The individuals that built the sales network for the company left the firm.

However, the representatives for those various regional firms began to show up at Emerson Equity. Individuals such as Shirley Wong and Peter Po came over from NI Advisors. Additionally, others came over from other firms that sold the L Bonds. They brought their reputation for failing to provide appropriate supervision over their clients to the firm that was selling the product that eventually failed.

These wholesalers that built the sales network for the product that eventually failed left the firm that sold the product. The representatives of those firms arrived and became part of the company that was selling the product. The firm shed its architects, and it absorbed its wreckage.

According to research published by FINRA into the industry, individuals who have previously entered into customer disclosure events are more likely to enter into another such event in their careers. Thus, rather than wonder if any of these individuals had a reputation of failing to provide appropriate supervision of their clients prior to joining Emerson Equity, the question that must be asked is whether or not anyone at the firm looked into these reputations before hiring these representatives.

In Part 4 of this article series, I will answer that question. For the person responsible for looking into the character of these representatives is also the person responsible for everything else that takes place at Emerson Equity. The sole CEO of the firm. The sole Chief Compliance Officer of the firm. The sole Financial and Operations Principal of the firm. The individual whose FINRA suspension for failure to supervise ran during the same month that HLEND broke escrow and began accepting investor capital. Furthermore, that individual took a $500,000 distribution from the firm in January of 2026, while arbitrations were pending against him and his firm, and while the firm had no reserves.

His name is Dominic Baldini. He will be the subject of Part 4 of this article.

NEXT

The Emerson Files, Part 4: “The Books”

The sole control person. The financials. The $0 reserves. The $500,000 distribution. The ownership of the company. A pending investigation with the SEC and FINRA. And a question that ties all of this together.

Charles Urquhart, CFA, is the founder of Fixed Income Resources, an independent educational publisher of fixed income literature. He is also an adjunct professor of Fixed Income Securities at Loyola University Maryland’s Sellinger School of Business. Mr. Urquhart spent 30 years in the financial industry. He worked for firms such as Kidder Peabody, Lehman Brothers, Fidelity Capital Markets, Tradeweb, and Andrew Davidson & Co. Mr. Urquhart does not have any position in HLEND, nor does he have any business relationships with Emerson Equity, HPS, or BlackRock. Additionally, he does not have any financial interest in any of the litigation that is occurring before the SEC and FINRA.

All of the legal issues referenced in this article pertain to unproven allegations. The settlements of the customers of these representatives that are referenced in this article are not admissions of wrongdoing. All of the information published in this article comes from the FINRA BrokerCheck report websites, the SEC, published case descriptions from the attorneys who are involved in these legal cases, and from InvestmentNews’ published report on the failure of the firm GWG.