The Securities and Exchange Commission (SEC) has launched legal proceedings against Bluesky Eagle Capital Management Ltd.

The case, filed on November 13, 2025 at the New York Southern District Court, concerns material misrepresentations and statements that could not be substantiated made by Bluesky, a purported investment adviser, in a form filed with the SEC and made available to the public on December 12, 2023, about Bluesky’s organization, office location, assets under management, and clients.

Specifically, Bluesky represented in its Form ADV (a form used by investment advisers to register with both the Commission and state securities regulators) that it is a public company operating out of office space on the 52nd floor of 140 Broadway, New York, New York 10005; that Joshua Troy Hunt serves as both its Chief Executive Officer (“CEO”) and Chief Operating Officer (“COO”); that it manages $10 million in assets in the United States; that it advises a private fund (with the same name as the defendant: Bluesky Eagle Capital Management Ltd.); and that a separate registered investment adviser (“RIA”) reports information about this private fund to the Commission on its own Form ADV.

The SEC argues that, contrary to Bluesky’s representations, the current real estate manager of 140 Broadway has no knowledge of Bluesky or its purported CEO/COO, and the separate RIA has not reported information about the purported private fund. Moreover, the Commission has not found any reporting of information about the private fund on other filings made with the Commission, and a search of the Commission’s public company database yields no information on Bluesky.

In addition, Bluesky failed to respond to a request by Commission attorneys to provide records to substantiate the information on the Form ADV, including the amount of private fund assets under management in the United States.

The SEC accuses Bluesky of violations of Sections 204(a) and 207 of the Investment Advisers Act of 1940 (the “Advisers Act”) [15 U.S.C. §§ 80b-4(a), 80b-7].

The Commission seeks a final judgment: (a) permanently enjoining Bluesky from violating the federal securities laws this Complaint alleges it has violated; (b) permanently enjoining Bluesky, its owners, and its executive officers, from filing a Form ADV as an exempt reporting adviser; (c) ordering Bluesky to pay a civil money penalty under Section 209(e) of the Advisers Act [15 U.S.C. § 80b-209(e)]; and (d) ordering any other and further relief the Court may deem just and proper.