Kai Stinchcombe

Kai H. Stinchcombe
Nationality	American
Occupation	Technology entrepreneur, CEO of True Link Financial
Known for	SEC settlement related to special needs pooled trust fraud
Alma mater	Massachusetts Institute of Technology

Kai H. Stinchcombe is an American technology entrepreneur and the founder and CEO of True Link Financial Advisors, LLC, a San Francisco-based registered investment adviser. In May 2022, the United States Securities and Exchange Commission (SEC) charged True Link and Stinchcombe in connection with a fraudulent scheme involving special needs pooled trusts operated by Synergy Settlement Services. True Link and Stinchcombe settled the charges, paying $200,000 and $20,000 in civil penalties, respectively, without admitting or denying the findings.

Early Life and Career

Kai Stinchcombe graduated from the Massachusetts Institute of Technology (MIT), where he studied economics, technology, and public policy with a focus on behavioral economics. Before founding True Link, he worked in consulting and analytics.

In 2012, Stinchcombe founded True Link Financial Advisors in San Francisco, California. The company developed specialized debit cards and financial accounts designed to protect elderly people and individuals with disabilities from financial exploitation. True Link positioned itself as a technological solution for vulnerable populations, offering tools that allowed caregivers and trustees to set spending controls and block common scam transactions. The company raised venture capital funding and established itself in the fintech space focused on elder financial protection.

Stinchcombe resided in Healdsburg, California, and built a reputation as an advocate for financial protections for at-risk populations.

Legal Case

The Synergy Settlement Services Scheme

Around 2018, True Link entered into a partnership with Synergy Settlement Services, a Florida-based company that operated pooled trusts for individuals with special needs through an entity called the Foundation for Those with Special Needs. Pooled special needs trusts allow people with disabilities to maintain eligibility for government benefits such as Medicaid and Supplemental Security Income while setting aside personal injury settlements or other funds for supplemental needs.

On May 2, 2022, the SEC announced charges against Synergy Settlement Services, Inc., the Foundation for Those with Special Needs, Special Needs Law Firm PLLC, and Synergy's CEO Jason D. Lazarus and president Anthony F. Prieto Jr. for fraudulently operating the pooled trusts. The SEC alleged that Synergy commingled trust assets with operating funds, charged excessive fees, and misled beneficiaries about how their money was being managed.

True Link's Role

In a separate but related proceeding, the SEC charged True Link and Stinchcombe with causing certain violations of the antifraud provisions of the federal securities laws. The SEC alleged that True Link served as the investment and asset manager for the pooled trusts and marketed its services to prospective Synergy clients in ways that reinforced the false impression that the Foundation for Those with Special Needs was a legitimate nonprofit pooled trust.

The charges alleged that True Link continued in its role despite warning signs that Synergy was improperly managing the trusts for its own profit. The scheme affected approximately 90 individuals with special needs, involving roughly $23 million in deposits.

Charges

The SEC charged True Link and Stinchcombe with violations of Section 17(a) of the Securities Act of 1933, Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5, and provisions of the Investment Advisers Act of 1940.

Outcome

True Link Financial Advisors agreed to pay a $200,000 civil penalty, and Stinchcombe personally agreed to pay a $20,000 civil penalty. Both settled without admitting or denying the SEC's findings and consented to a cease-and-desist order prohibiting future violations of the relevant securities laws.

The primary defendants in the case faced more severe consequences. The SEC's complaint against Synergy Settlement Services, Jason Lazarus, and Anthony Prieto alleged a broader pattern of misconduct in the management of funds belonging to some of the most vulnerable members of society.

Stinchcombe has continued to operate True Link Financial following the settlement, and the company continues to offer financial management tools for vulnerable populations.