United Development Funding IV fka UDFI

[Jh5142]

Based upon my understanding of reading the transcripts from the Detention Hearing:

The SEC and Management agreed to a civil settlement of $7.2 million. The intention was for management to disgorge certain profits and pay that money to investors.

Apparently, the funds for much of this payment came from CTMGT Travis Ranch. So the proceeds from a loan to CTMGT Travis Ranch, along with some other UDF cash was the source of the $7.2 million.

So, apparently, they had UDF IV pay their $7.2 million settlement for the benefit of investors in UDF IV?

Is it fair to say the SEC settlement and associated payments were a Ponzi-like scheme?