You can’t blame Oren Eugene Sullivan for being a little cocky. The former NYLife Securities broker in Rock Hill, S.C., managed to pull the wool over his clients’ eyes for two decades before his Ponzi scheme was finally uncovered last year by a suspicious great-grandmother and her skeptical daughter.  

Sullivan, 63-years-old, has now been permanently barred from the industry by FINRA. In a related criminal case, Sullivan has been indicted by the U.S. Attorney’s office in South Carolina. On August 20, he was charged with seven criminal counts for operating the Ponzi scheme. Each count carries a maximum fine of $250,000 and a 20-year prison sentence.

According to an announcement today by FINRA, Sullivan allegedly misused $3.7 million from more than 30 clients over a 20-year period. His victims included 15 widows and two clients who suffered from Alzheimer’s. Twelve of the clients were over 70-years-old, and a number of them considered Sullivan to be a close family friend, according to a FINRA press release.

Sullivan’s lawyer couldn’t be reached for comment.

Between 1988 and October 2008, Sullivan allegedly stole clients’ money by making them believe they were investing in promissory notes and other products. He gave his clients a one-page “note” stating the amount of principal and a guaranteed annual interest rate ranging from 6% to 12%. The clients paid for the notes with personal checks made out to a fictitious corporation.

FINRA contends that Sullivan deposited the checks into a personal account and used the money to pay his children’s school fees and buy cars. Eventually he had to use the money from newer clients to pay the obligations of older clients, the regulatory agency alleged.

His scheme was discovered when one client realized he had stolen $10,000 she had given him to buy variable annuities for the benefit of her great-grandchildren. Instead of buying the annuities, Sullivan had used the funds to pay for his son’s wedding. The client and her daughter became suspicious when they realized that they hadn’t received a single statement showing the investment performance of the securities, despite repeated requests.

They confronted Sullivan at his office. He attempted to placate them with a $10,000 interest-bearing note, and then tried to avoid being caught by his bosses by giving them a fabricated letter he claimed was from his compliance department. The letter said he had already been reprimanded for misappropriating the funds. But the pair was having none of it— they contacted Sullivan’s managers, who subsequently uncovered the scheme.

Sullivan allegedly obtained approximately $3.7 million in this way and owed around $2.2 million at the time he was caught.

NYLife has reimbursed the affected customers.

“The protection of seniors and other vulnerable investors from unscrupulous brokers remains one of FINRA’s highest priorities and we will continue to identify and expel those within our jurisdiction who take unfair advantage of their clients,” said Susan L. Merrill, FINRA’s chief of enforcement, in a statement.