First Liberty Building & Loan: 15-Year Sentence, $76,454,374.39 Restitution, Claims Bar Date December 26, 2026

What this page is, and the rule it follows

Three government sources describe First Liberty, and they do not use the same numbers. The Justice Department reports the criminal sentence. The SEC filed the civil case and its complaint is an allegation; the company and its founder consented to relief without admitting or denying it. The court-appointed receiver reports to the court every quarter on what he holds and how claims will work. We name companies, agencies, courts and case numbers, not victims or relatives, and we call the company's founder "the founder" except in the case captions.

The SEC complaint does not refer to a registration or a Form D, and an EDGAR company search for the name returned no filings on November 6, 2026 (saved in our sources), so there is no prospectus to read. The primary documents here are court papers: the Justice Department's April 23 and October 26, 2026 releases, the government's sentencing memorandum (ECF 21), the SEC complaint (ECF 1) and release LR-26358, the receiver's first to fifth reports (ECF 32, 73, 85, 110 and 141), his motion to approve a claims process (ECF 117) and the receiver's website. We did not read the October 27, 2026 order approving the claims process (ECF 139) itself; the schedule below comes from the receiver's October 30 report, which quotes it.

The case in dates

Three documents, three sets of numbers

The documents do not explain the gaps. Two readings are possible and we cannot tell which applies: the Justice Department and SEC may count each person behind an entity or account while the receiver counts accounts, and the receiver's $66 million is a floor ("at least") while the restitution figure comes from the criminal case's own loss calculation. Both are our reading, not something any of the documents says. The practical consequence is simple: your claim amount is the receiver's net-loss figure for you, not the restitution total and not the SEC's raised amount.

Of the $155 million-plus the receiver says came in, about $89 million went back out before the receivership. Per $1,000 sent in, that is at most about $574 returned before the receiver was appointed, and a net loss of about $426 (our arithmetic, using the receiver's rounded figures).

What First Liberty sold, as the documents describe it

The SEC complaint says First Liberty sold two products, loan participation agreements and promissory notes, with annual returns of 8% to 18%, and that investors were told the money would fund short-term “bridge loans” to small businesses that SBA or other commercial loans would refinance. Both products “were purportedly to fund Bridge Loans”. Until 2024 the complaint says they were sold to “friends and family”; from 2024 it says the company advertised the notes on radio, podcasts and its website.

The receiver found something that matters to every holder. Investors who signed participation agreements believed their money was tied to particular loans. His first report says the opposite: “all funds received were pooled and comingled with other investor funds and that loans were made from a common fund.” He also reports that “not a single loan held by the Receiver is current on payments”, that in October 2025 the main asset was about 60 defaulted loans, and that interest kept being paid to investors out of the common pool after loans defaulted. He told the court it was “vital to have the Bridge Loans administered by court-appointed fiduciary in a single proceeding”, and his later motion proposes one claims process for all investors.

The Justice Department release says the founder spent at least $5 million of investor funds on himself, including more than $2 million of credit card payments and more than $570,000 of political contributions, and described the scheme as a Ponzi scheme. In the plea agreement the parties agreed that the loss was more than $65 million and under $150 million. The U.S. Attorney is quoted in the Justice Department release calling the conduct a “stunning, sinful, and sacrilegious abuse of trust.”

The sentence, in numbers

The sentence is 12 months longer than the government asked and 55 to 60 months under the Guidelines range (our arithmetic). A restitution order is a judgment against the defendant. The Justice Department release does not say what he owns, how much can be collected, or how restitution payments will relate to the receiver's claims process, and we found no document that does.

The claims process: dates and rules

The receiver's fifth report (ECF 141, October 30, 2026) says the court entered the Order Approving Claims Process on October 27, 2026 and prints this schedule, counted in days from the order:

The report prints the Day 110 date with the year 2026, which is an evident typo: 110 days after October 27, 2026 is February 14, 2027 (our arithmetic). The court asked for changes to the receiver's proposed order at the October 8, 2026 hearing, so details below that come from his August 6, 2026 motion may differ in the final notice you receive. Where they do, the notice and the order control.

How your claim is calculated, as proposed

• Net loss, nothing else. The receiver subtracts everything you received from the First Liberty companies from everything you sent them, "regardless of how those transfers were categorized", a "simple money-in, money-out" calculation. Interest or profit promised but not paid is not part of the claim.
• Pre-filled for most. He expects "the vast majority of Investors" to receive a form with the amount already calculated and a transaction report. You either accept it or dispute it with your own figures and documents. Investors he cannot calculate get a blank form.
• Accounts are netted. If you hold more than one account, including an IRA, a trust, a joint account or a one-person LLC, the claim is total deposits minus total withdrawals across all of them.
• Report other recoveries. You must tell the receiver about money you got back from anyone else, and it is deducted. That includes any repayment under the Bankers Life agreement described below.
• Who cannot claim. A claimant certifies that they were not an insider of First Liberty or its affiliates and did not knowingly assist the scheme. A claim that fails the test can be disallowed.
• Deadline mechanics, as proposed. The motion says a completed form must be sent by trackable physical mail, postmarked by the bar date, to First Liberty Claims, c/o Hays Financial Consulting, LLC, 2964 Peachtree Rd. NW, Suite 555, Atlanta, GA 30305, and that later claims are barred except for good cause in the receiver's sole discretion. The motion also says elsewhere that forms must be "received" by the deadline, so read your own notice for which rule applies.
• Disputes. The receiver decides disputed claims by the final determination date and tells you why he rejected one. You can appeal to the court by mail; the court's decision is final.

How money would be shared, if the court agrees

The receiver says the net-loss figure only sets each claim. For paying out he proposes the "rising tide" method, subject to later court approval, which counts what each investor already received before the receivership so that investors recover about the same percentage of what they put in. He reserves the right to use a different method.

Example (our arithmetic, not from any filing). Investor A sent $100,000 and got $60,000 back before the receivership. Investor B sent $100,000 and got nothing back. If $100,000 were available: a plain pro rata split by net loss ($40,000 and $100,000) would pay A $28,571 and B $71,429. A rising-tide split pays A $20,000 and B $80,000, so each ends with $80,000 back of $100,000 (80%). If only $50,000 were available, B would get all of it and A nothing yet, because B has to reach A's 60% first.

What the receiver holds

Line 9 of the fund accounting, "Disbursements to Investors", is $0.00 for all periods through September 30, 2026. The receiver has not paid investors anything yet. Separately, the receiver says the Georgia Secretary of State announced an agreement with Bankers Life to repay nearly $6.7 million to more than 40 investors, that claim forms for it went out in June 2026 and that checks were mailed in September 2026. He says those payments reduce the claims that will remain.

The $4,831,779.41 includes $2,397,680.61 that a borrower, 2406 Cancer Care LLC, wired to the receiver on December 30, 2025 and says satisfies what it owed. The receiver disputes that it resolves all issues and the dispute was unresolved on October 30, 2026. Without it the cash would be $2,434,098.80 (our arithmetic).

What else the fifth report lists, with the receiver's own caveats:

None of these is cash yet except the equipment sale. Adding every item above to the cash does not give a recovery figure: they overlap with litigation, carry legal costs, and the report does not state the total of court-approved fees paid in the reporting period in a form we could read reliably.

Your money, per $1,000 (our arithmetic)

• Before the receiver: the receiver's totals mean at most about $574 of every $1,000 sent in was paid back before July 2025, and the net loss was about $426 per $1,000 (89 of 155 million, rounded).
• Cash today against the loss: $4,831,779.41 is about 7.3% of the receiver's $66 million net-loss floor, or about $73 per $1,000 of loss. That is a ratio of two numbers, not a payout forecast: it ignores fees, the other assets above, and the fact that the $66 million is "at least".
• An illustration of the claim: an investor who sent $400,000 in three deposits and received $96,000 in monthly interest would see a pre-filled claim of $304,000. Interest the contract promised but did not pay would not be added, and under a rising-tide plan the $96,000 already received would count toward that investor's share.

What we could not verify

• The text of the October 27, 2026 Order Approving Claims Process (ECF 139) and the final notice and claim form. The schedule is from the receiver's report; the method is from his motion, which the court asked him to change.
• Whether the claims packages were in fact mailed on or before November 6, 2026. That is the receiver's stated deadline, and the date of this page.
• How restitution of $76,454,374.39 will be collected or paid out, and how it interacts with the receivership.
• The SEC's monetary remedies. The defendants consented to relief in July 2025 with the amounts left for the court; we found no later judgment in the documents we read.
• Why the investor and loss counts differ between the SEC, the Justice Department and the receiver.
• The Georgia Secretary of State's own notice, which our fetch could not open. The Bankers Life figures are the receiver's description of it.

What a reader can do with this

This page does not tell you what a claim is worth or whether to file one. Here is what the record supports.

1. Watch for the package. The order calls for first class mail to the last known address by November 6, 2026. If you moved since you invested, tell the receiver. His published contact is FirstLibertyInquiries@stretto.com or 404-926-0060; he asks you to search firstlibertyreceivership.com first, and its investor contact form is on the front page.
2. Open the pre-filled amount and check it. Compare the deposits and withdrawals with your own bank records. The receiver's first letter to investors asked you to keep check copies (front and back), wire transfers and correspondence and account statements. Add Bankers Life or any other money you recovered.
3. Count the days. December 26, 2026 is a Saturday, and the documents we read do not say how a weekend bar date is applied. The notice you receive is the document that controls.
4. Know the limit on what he can tell you. The receiver says he is not your lawyer and cannot give legal advice, and he cannot predict amounts or timing of distributions.
5. Follow the docket. The receiver's site lets you subscribe to filings by email. On the quarterly pattern the next report is due about January 30, 2027.
6. Read how other receiverships treat the same questions. Our pages on the Wells Real Estate Investment receivership, the SQN Capital Management receiver and Pacific Private Money Group set out different claims rules; for the product itself see real estate notes investing and private money lenders, and for notes held inside a retirement account see the self-directed IRA rules.
7. Tax and legal questions. How a loss, a restitution payment or a receiver distribution is treated is a matter for a tax professional or lawyer who can see your statements; we did not research it for this page.

FAQ

All figures are from primary documents read on November 6, 2026: the Justice Department releases of April 23 and October 26, 2026 (U.S. Attorney's Office, Northern District of Georgia); the government's sentencing memorandum (ECF 21) in United States v. Frost, No. 3:26-cr-00008 (N.D. Ga.) and its CourtListener docket; the SEC complaint (ECF 1) and Litigation Release LR-26358 in SEC v. Frost and First Liberty Building & Loan, LLC, No. 1:25-cv-03826 (N.D. Ga.); and from the receiver's website, firstlibertyreceivership.com, his investor letter of July 16, 2025, FAQ, five quarterly reports (ECF 32, 73, 85, 110 and 141) and his motion to approve a claims process (ECF 117). This is analysis of public documents, not investment, legal or tax advice.