UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934 

Release No. 92140 / June 10, 2021

ADMINISTRATIVE PROCEEDING

File No. 3-16941

In the Matter of

Scott A. Doak,

Respondent.

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ORDER ESTABLISHING A 

FAIR FUND

On November 4, 2015, the Commission issued an Order Instituting Administrative and 

Cease-and-Desist Proceedings Pursuant to Section 8A of the Securities Act of 1933, Section 21C 

of the Securities Exchange Act of 1934, Sections 203(f) and 203(k) of the Investment Advisers 

Act of 1940, and Section 9(b) of the Investment Company Act of 1940, Making Findings, and 

Imposing Remedial Sanctions and a Cease-and-Desist Order (the “Order”)1 against Respondent. 

In the Order, the Commission found that, from at least 2010 through 2014, William M. 

Apostelos (“Apostelos”) and companies he controlled violated the registration and anti-fraud 

provisions of the federal securities laws by conducting fraudulent, unregistered offers of 

securities and misappropriating investor funds to pay earlier investors and promoters, finance 

other businesses he and his wife owned, and pay his personal expenses. Doak, an emergency 

medicine physician, became a client of Apostelos no later than 2007. According to the Order, in 

early 2013, Doak, Apostelos, and other individuals began operating OVO Wealth Management, 

LLC (“OVO”), a state-registered investment adviser. After approximately a year of operations, 

OVO was wound down, and Doak made oral and written misrepresentations and omissions to 

OVO clients to induce them to transfer their advisory accounts to investments controlled by 

Apostelos. 

The Order found that Doak violated the registration provisions of the federal securities 

laws by offering and selling securities issued by entities controlled by Apostelos. Doak and 

OVO also violated the anti-fraud provisions of the federal securities laws by making 

misrepresentations and omissions while advising OVO clients to invest their advisory accounts 

in investments controlled by Apostelos. Through the same conduct, Doak aided and abetted and 

caused the violations of Apostelos and OVO. 

 

1

 Securities Act Rel. No. 9976 (Nov. 4, 2015).
2

The Commission ordered Respondent to pay disgorgement of $86,833.34, prejudgment 

interest of $2,874.44, and civil penalties of $160,000.00, for a total of $249,707.78, to the 

Commission, pending a decision whether the Commission would seek to distribute funds or 

transfer them to the U.S. Treasury. 

Respondent has paid in full. The Commission currently holds the $249,707.78 paid by 

Respondent in an interest-bearing account at U.S. Department of the Treasury’s Bureau of the 

Fiscal Service.

The Division of Enforcement recommends that a Fair Fund be established, pursuant to 

Section 308(a) of the Sarbanes-Oxley Act of 2002, so that the civil money penalty paid, along 

with the disgorgement and prejudgment interest paid, can be distributed to harmed investors.

Accordingly, IT IS HEREBY ORDERED, that pursuant to Section 308(a) of the 

Sarbanes-Oxley Act of 2002, a Fair Fund is established so that the civil money penalty paid, 

along with the disgorgement and prejudgment interest paid, can be distributed to harmed 

investors.

By the Commission. 

Vanessa A. Countryman

Secretary