Cameron High, 38, participated in a fraud by which his firm, Yellowstone Partners of Idaho, systematically overbilled more than 100 of its clients' accounts by US$11.8 million. He was, during much of the time, the chief compliance officer and has now been banned from financial services by the US Securities and Exchange Commission.

During the time of the fraud, to which American and British regulators always refer as the "relevant period," Yellowstone was owned by David Henry Hansen (90%), by his subordinate Cameron High (5%), and by its chief investment officer, whose name is not recorded (5%). As the owners, both Hansen and High received a percentage of Yellowstone’s profits, which came largely from the advisory fees that they charged their HNW clients.  

Both Hansen and High were responsible for obtaining Investment Advisory Agreements or IAAs from each of their clients and knew of Yellowstone’s procedures and the rules to be found in the Advisors Act 1940, but failed to follow them.

At other times during the Relevant Period, Hansen instructed High to submit billings in addition to the annual and quarterly fees., claiming that they were for extra work. High submitted these bills at Hansen’s behest without question, although nobody at Yellowstone performed any extra work. Hansen also bypassed High on several occasions and personally submitted extra bills (also for work not done) to Raymond James & Associates, a broker-dealer registered with the SEC at which approximately $476 million in client assets was held in custody.

Sometimes Hansen instructed Raymond James to deposit overbillings into his own personal account, thereby also bypassing Yellowstone’s accounting or notice. High thought that at least some of the extra billings were suspicious, but did not ask Hansen about them and did nothing to verify the performance of extra work.

Several clients questioned Yellowstone about overbillings.  When confronted, Hansen (or High at his behest) claimed that the overbillings were the result of inadvertent error and Yellowstone then refunded the fees.

To take one example, in or around May 2013, Hansen directed High to overbill fees to a particular family’s accounts by $83,547.26, saying that the amount was an “origination fee.” High did not question Hansen and instructed Raymond James by email to charge the fees to the accounts. The family’s accountant later questioned the fees and Yellowstone refunded them, claiming error on the part of the custodian.

75.Hansen and High caused Raymond James to bill Yellowstone clients in their respective accounts for unearned fees.  Through their actions, Defendants caused over $11.8 million in unearned fees to be assessed and taken from client accounts and transferred to Yellowstone’s or Hansen’s accounts.

High was an investment advisor representative at Yellowstone between July 2006 and March 2017 (when Yellowstone was sold) and was a registered representative associated with broker-dealers registered with the SEC between April 2006 and October 2017. He lives in Idaho Falls. He acquired his stake in Yellowstone sometime in 2012. On 14 March he pled guilty to one countof wire fraud in contravention of Title 18 United States Code, section 1343, before the United States (i.e. federal) District Court for the Northern District of Idaho. He is expected to be sentenced next year.

The SEC has barred High from association with any broker, dealer, investment advisor, municipal securities dealer, municipal advisor, transfer agent, or nationally recognised statistical rating organization. Any reapplication for these privileges will be subject to the applicable laws and regulations governing the re-entry process.