CO,
The point is Rhonda was the compliance officer at the time of the infraction. No doubt she was asked questions and it impacted the firm. I bet she did not tell you that Flanders left on good terms. Then why hire him? Why not address it? If it was no big deal it should of been said. Ask Justine at SCA (is that a owner? secratary?) if she would hire Flanders as the sales manager? The compliant is the formal action after the investigation and the event took place under Rhondas watch.
The Commission's complaint alleges that from approximately late 2001 through September 30, 2003, Gross, along with Telvest and his wholly owned entity Morgan Spaulding, engaged in a deliberate scheme to defraud overseas purchasers of Regulation S stock. These defendants facilitated the sale of nearly $15 million in unregistered shares of U.S.-based companies to overseas investors by, among other things, deceiving the investors into believing that nearly all of the stock purchase price would be remitted to the companies issuing shares. Transaction confirmations sent to investors disclosed only a fee of either one percent of the purchase price or a flat $50, concealing the fact that approximately 55 to 70 percent of the purchase price would be paid to Gross, Morgan Spaulding and Telvest; to overseas brokerage firms as undisclosed commissions; and as "finder fees" to promoters including defendant John Flanders. In truth, only about 30 to 45 percent of the invested proceeds actually made it to the issuers. The complaint alleges that Telvest and Flanders acted as unregistered broker-dealers in connection with the fraudulent transactions.
