No One

[Outlaw]

In the Matter of
INTERNATIONAL CAPITAL
GROUP, LLC,

http://www.sec.gov/litigation/admin/2015/33-9717.pdf

9. The loans were nonrecourse: in the event of default, which could be triggered,
inter alia, by a 60 percent decline in the price of the collateral stock, the debtor had the option to
tender additional collateral or to forfeit the securities with no contingent liability.

14. On average, ICG began selling shares associated with each loan three days prior
to loan closing and funding, and completed the sale of all remaining collateral within two weeks
of receiving the stock from the customer. In many instances, ICG did not wire funds to the
customer from its bank account until it had sold sufficient collateral shares in its brokerage
account to generate an equivalent amount of proceeds. ICG’s principals personally oversaw and
authorized sales of stock by ICG.

16. Unlike a traditional lender, ICG generated relatively little of its cash flow from
the customers’ payment of interest, fees, or repayment of principal. In addition, because ICG
expected many of its loans to default, it generally did not maintain cash reserves to return
collateral shares at maturity