Cogo Capital Review: 259 Loans in 2024 (HMDA), Its Fund's SEC Offering Declared Abandoned in 2025

Who is Cogo Capital legally?

The website's terms of use say they are "between you and Cogo Capital, LLC", and the footer lists NMLS #1760709, an Arizona mortgage broker licence and a California Finance Lenders licence, with a link to "the Secured Investment Corp NMLS Consumer Access Page". The privacy policy (last modified December 13, 2023) names one group, "The Secured Investment Corp. Family of Companies". The documents we could read tie the pieces together:

Two small inconsistencies are worth knowing. The offering circular calls the manager a Wyoming corporation in one place and an Idaho corporation in another, and the GLEIF legal address is a Wyoming registered-agent address while the operating address is in Idaho. We did not pull a Secretary of State certificate for either state. The website's own About page says "Since 2017" for the lender; the offering circular describes a 2012 loan taken "to fund the development and expansion of Cogo Capital business operations and franchise", so the name is older than the About page implies (that expansion was "abandoned").

HMDA 2024: what the loan-level file shows

Secured Investment Corp. is on the 2024 FFIEC filer list (4,927 institutions) under LEI 2549003K48UGTWEK6O31, which GLEIF ties to the name Cogo Capital. It is not on the 2025 list (4,791 institutions) as of November 10, 2026. We searched the 2025 list for the LEI and for the names "Secured", "Cogo" and "Lake City Servicing" and found no match. We cannot tell from the data why; we state only that no 2025 record is available to compare.

Reading it: only 259 of 2,051 records, 12.6% (our arithmetic), became a loan, and 1,789 (87.2%) were withdrawn or closed incomplete, and all 2,051 records are reported as submitted directly to the lender; HMDA does not say why so many were withdrawn. All 259 originated loans carry purchaser code 5, which the HMDA code list defines as a private securitizer: every loan was reported as sold within the year, none kept on the lender's own books. The 2024 originated volume of $41.5 million sits beside the website's claim of "$164M Million Invested" and "1,968 Loans Approved", with no period given. We cannot test the cumulative claim; the HMDA figure covers one year and one reporting entity only.

The advertised terms and the filed terms line up loosely. The site's bridge and flip program says maximum loan-to-value 70%, 12-month maximum term, and rates "Starting at 10.99% and 1.99 Origination Points", with a footnote that this rate is only for borrowers who have paid off two Cogo deals. HMDA shows a median rate of 12.49% and a maximum LTV of 115.67%, which probably reflects a combined or after-repair basis; the field definition does not tell us.

Published terms, read November 10, 2026

The site says loans are for non-owner-occupied investment property and "must be made through a borrower entity". It operates mainly as a wholesale lender through brokers ("Where We Broker"), with the Arizona licence stated for Arizona.

The fund's offering circular adds a fee the website does not highlight: an origination fee of $997 for each $300,000 of principal, collected by the manager as Cogo Capital and split 80% to the manager and 20% to the fund. On a $450,000 loan that is two steps, $1,994 (our arithmetic from the circular's fee table, which lists $1,994 for loans of $300,001 to $600,000). Ask the broker for the full closing-cost estimate; a flat processing fee comes on top of the points the site quotes.

The education business and who gets the higher leverage

The offering circular states that the manager, "operating under a fictious business name of The Lee Arnold System of Real Estate Investing", offers educational real estate programs and seminars, that they "operate separately and independently from the Company", and that the fund "may make Loans to real estate investors who have attended" them. It describes Master Rehabber and other certifications, a three-day program near Spokane, Washington, and one-on-one mentorship, all "offered for a fee". The loan table then sets a 70% maximum LTV for "borrowers who have completed the specific real estate education programs", with the weighted portfolio target at 60% to 65%. In one passage the circular says there are "no additional benefits or preferential treatments" to program participants beyond the stated ratio; in the risk section it lists "Higher Loan-to-Value ratios of Arnold Program" participants as a risk. The website says its "education students can receive special lending terms, such as a lower FICO score requirement".

For a borrower this matters in one way: a lender whose operator also sells training has a reason to market to people who are new to flipping. That is not wrongdoing, and the filings say the fees from the courses are not payable to the fund. It is a reason to read your own loan documents for default and extension terms before you rely on a brochure.

Sponsor record: the Circle of Wealth Fund III filings

Circle of Wealth Fund III is not the lender, but it is the one place where Secured Investment Corp. files with the SEC, so it is the only independent view of the company that we have. All figures below are the fund's, not the lender's.

Three events matter more than the balance sheet.

1. 2015 Washington consent order. The offering circular discloses that on January 7, 2015 the manager and its president entered a consent order with the Washington Department of Financial Institutions after the regulator alleged a referral program violated the registration and anti-fraud provisions of the Business Opportunity Fraud Act. The order told them to cease and desist and pay $1,500 for investigation costs. The same document says the 2019 offering statement left this out, so the fund offered to repurchase 625 interests sold between August 30 and December 20, 2019 to 65 persons: a possible payment of $625,000 plus about $12,550 of statutory interest, $525,000 of which the manager guaranteed to fund, with $16,666.10 paid to date. We did not retrieve the order itself; the description is the company's own.
2. June 27, 2025 SEC order. The manager filed an amended Form 1-A on August 22, 2024 to put the rescission terms into the offering circular. On June 27, 2025 the SEC issued an order under File No. 024-12492 stating "The offering statement has been on file for more than nine months and has not yet been qualified" and declaring it "abandoned". An abandoned offering statement is a housekeeping outcome, not a finding of misconduct; it does mean the rescission terms were never qualified.
3. July 2025 subpoena. The October 3, 2025 semiannual report says that on or about July 24, 2025 the fund "received a subpoena from WA DFI requesting documents and information related to sales of securities in Washington State", with a temporary stay while an examiner reviews the file, and that the fund intends to file a new Form 1-A. We found no later filing: the latest EDGAR entry for the fund is that October 3, 2025 report, and no annual report for fiscal 2025 (due around April 30, 2026 for a Tier 2 issuer) appears. The earlier Secured Investment High Yield funds last filed in 2019.

None of this concerns a borrower's loan directly. It tells you that the company behind the lender has had a regulator order, an unqualified offering and an open state inquiry, all disclosed by itself. A borrower is not an investor in the fund, and the lender may fund loans from other sources.

What we did not find

Our EDGAR and web searches turned up no SEC or FTC enforcement action naming Cogo Capital or Secured Investment Corp., but we did not run a docket search (CourtListener needs a login) and did not query CFPB complaints, so we make no statement about civil cases or complaint counts. We did not verify the NMLS or state licence numbers against the registers, and we do not use review-site counts. A company with real filings can still have disputes the filings do not mention; ask for references.

What a reader can do with this

• Confirm the lender's licence for the property's state on NMLS Consumer Access and the state regulator before you pay an appraisal or application fee.
• Ask which entity is the lender of record on your term sheet (Cogo Capital, LLC, Secured Investment Corp. or a fund) and who services the loan (Lake City Servicing is the servicing name in the filings).
• Ask whether the 10.99% rate applies to you, and for the total of points, the $997-per-$300,000 processing fee and any extension fee on a 12-month loan.
• If you also took a course from the education arm, keep the course agreement separate from the loan file, and do not assume the higher leverage is offered outside that route.
• Compare at least two other lenders, for example Kiavi, Lima One Capital, Visio Lending or the lender Loan Ranger Capital, and see our list of hard money lenders.

FAQ

Sources, read November 10, 2026: cogocapital.com (loan programs, about, privacy policy, terms of use, where we broker); GLEIF record 2549003K48UGTWEK6O31; FFIEC HMDA data browser, 2024 loan-level file and 2024 and 2025 filer lists; SEC EDGAR for Circle of Wealth Fund III LLC (CIK 0001762825): Form 1-A accession 0001731122-24-001307, Form 1-K accession 0001213900-25-039335, Form 1-SA accession 0001213900-25-095796, SEC order accession 9999999997-25-002796. This is analysis of public documents, not investment, legal or tax advice.