SEC Wins Default Judgment Against Bluesky Eagle Capital Management Over False SEC Filings

Key Takeaways

• Form ADV Integrity Is Non-Negotiable: The SEC’s case centered on alleged material misstatements in Bluesky Eagle’s December 2023 Form ADV, reinforcing that adviser disclosures are not marketing documents but regulatory filings subject to enforcement scrutiny.
• Regulatory Status Misrepresentation Carries Consequences: The firm allegedly claimed Exempt Reporting Adviser status, public company standing, and $10 million in U.S. assets under management without substantiation, exposing significant governance and credibility gaps.
• Verification Extended Beyond the Filing Itself: The SEC’s complaint detailed cross-checks with a New York property manager, another registered investment adviser, and the Commission’s own public databases, none of which supported Bluesky Eagle’s representations.
• Failure to Respond Amplified Risk: The SEC alleged the firm did not provide records requested by Commission attorneys to substantiate its Form ADV statements, a breakdown that escalated the matter to a default judgment.
• Permanent Bar and Seven-Figure Penalty: The court permanently enjoined Bluesky Eagle from future violations of Sections 204(a) and 207 of the Investment Advisers Act of 1940, barred it and its leadership from filing Form ADV as an Exempt Reporting Adviser, and imposed a $1,182,254 civil penalty.

Deep Dive

A federal judge in Manhattan has handed the U.S. Securities and Exchange Commission a win in its case against purported investment adviser Bluesky Eagle Capital Management, entering a final judgment by default after the firm failed to defend itself against allegations that it made material misrepresentations in an SEC filing.

According to the SEC’s litigation release, the U.S. District Court for the Southern District of New York entered the default judgment on February 11, 2026. The enforcement action stems from a complaint the Commission filed on November 13, 2025.

The case was largely about Bluesky Eagle’s December 2023 Form ADV, which is a disclosure document that investment advisers use to provide regulators and the public with key information about their business, assets, and regulatory status.

In its complaint, the SEC alleged that Bluesky Eagle’s Form ADV contained a series of material misrepresentations and unsubstantiated claims.

Among them, the firm represented that it:

• Qualified as an Exempt Reporting Adviser, a category of private fund advisers that are not required to register with the SEC.
• Was a public company operating from office space in New York City.
• Managed $10 million in assets in the United States.
• Advised a private fund.
• Had information about that private fund reported by a separate registered investment adviser on its own Form ADV.

The SEC alleged that those statements did not hold up under scrutiny.

According to the complaint, the real estate manager of the purported New York office space said it had no knowledge of Bluesky Eagle or its alleged executives. The separate registered investment adviser named in the filing had not reported information about the purported private fund, the SEC alleged. The Commission further stated that it found no reporting about the private fund in other SEC filings and that a search of its public company database yielded no information on Bluesky Eagle.

The complaint also alleged that Bluesky Eagle failed to respond to a request from SEC attorneys to produce records substantiating the information contained in its Form ADV.

The Court’s Order

With Bluesky Eagle not appearing to contest the case, the court entered judgment by default.

The final judgment permanently enjoins the firm from future violations of Sections 204(a) and 207 of the Investment Advisers Act of 1940. It also permanently bars Bluesky Eagle, its owners, and its executive officers from filing a Form ADV as an Exempt Reporting Adviser.

In addition, the court ordered the firm to pay a civil penalty of $1,182,254.

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