Individual investors are likely to bear the cost of Terry Serepisos' $2 million debt to Waipukurau law firm DAC Legal's nominee company.
An investors' guide said funds were pegged to individual mortgages, such as the lending to Serepisos.
DAC typically would charge borrowers such as Serepisos 9 per cent interest but paid investors 6 per cent.
Mortgage manager Stephen Smith handled the day to day aspects of investing and was the liaison person in regards to investments with Midlands Mortgage Trust.
Midlands recently froze more than $40 million of investors' money after Serepisos' bankruptcy last week.