UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934

Release No. 88964 / May 28, 2020

ADMINISTRATIVE PROCEEDING 

File No. 3-19227

In the Matter of

FIELDSTONE FINANCIAL 

MANAGEMENT GROUP, LLC, and 

KRISTOFOR R. BEHN

Respondents.

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 ORDER DIRECTING 

DISBURSEMENT OF FAIR FUND 

On December 23, 2019, the Commission published a Notice of Proposed Plan of Distribution 

and Opportunity for Comment (“Notice”),1pursuant to Rule 1103 of the Commission’s Rules on Fair 

Fund and Disgorgement Plans (“Commission’s Rules”).2 The Notice advised interested persons that 

they could obtain a copy of the Proposed Plan of Distribution (“Proposed Plan”) from the 

Commission’s public website or by submitting a written request to Noel Gittens, United States 

Securities and Exchange Commission, 100 F Street, NE, Washington, DC 20549-5876. The Notice 

also advised that all persons desiring to comment on the Proposed Plan could submit their comments, 

in writing, within 30 days of the Notice. The Commission received no comments on the Proposed Plan 

during the comment period. On February 20, 2020, the Commission issued an order approving the 

Proposed Plan,3and posted the approved Plan of Distribution (the “Plan”).

 

1

 Exchange Act Rel. No. 87854 (Dec. 23, 2019).

2

 17 C.F.R. § 201.1103.

3

 See Order Approving Plan of Distribution, Exchange Act Rel. No. 88249 (Feb. 20, 2020).
2

The Plan provides for the distribution of the Net Fair Fund4to forty (40) investors who paid 

$84,778 of advisory fees to the Respondents, and the net amount of $900,000 obtained from one (1) 

investor in Fieldstone (the “Eligible Investors”) up to each Eligible Investor’s total Harm Amount, plus 

reasonable interest. Since the total Harm Amount incurred by the Eligible Investors ($984,778) 

exceeds the amount currently in the Net Fair Fund ($684,047) this initial distribution from the 

available funds will be made on a pro-rata basis. 

Pursuant to the payment schedule in the Order, receipt of additional funds is anticipated.

Therefore, after receipt of any additional funds, a second distribution will be made, which will provide 

a total distribution amount up to each Eligible Investor’s total Harm Amount, plus reasonable interest.5 

Pursuant to the Plan, the Fund Administrator has compiled the payee information and prepared 

the payment file in a Commission-approved format. The Commission staff has reviewed the payment 

file and requests that, pursuant to Rule 1101(b)(6) of the Commission’s Rules on Fair Fund and 

Disgorgement Plans,6the Commission direct the payment of $684,047 from the Fair Fund for 

distribution by the Fund Administrator to the Eligible Investors in accordance with the Plan

Accordingly, it is hereby ORDERED that Commission staff shall direct the payment of 

$684,047 from the Fair Fund to the Eligible Investors in accordance with the Plan.

By the Commission.

Vanessa A. Countryman

Secretary

 

4

 All capitalized terms used herein but not defined shall have the same meanings ascribed to them in the Plan.

5

 Reasonable interest will be calculated using the short-term Applicable Federal Rate compounded quarterly from the 

midpoint of the trading period in which the harm occurred through August 31, 2019.

6

 17 C.F.R. § 201.1101(b)(6).