did Curt and Seth Kramer start KBM under Seth's name just to get around the SEC restrictions placed on him and companies doing business with Curt Kramer by FINRA? That's a reasonable supposition. Though the underlying action was brought by the SEC. https://www.sec.gov/News/PressRelease/Detail/PressRelease/1370540410863 There's also a more recent action involving SPNG, though the case goes back to 2008-2009: https://www.sec.gov/litigation/admin/2016/33-10239.pdf