Regulator Statement
SHORT HAS SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE SEC HAS
DETERMINED TO ACCEPT. WITHOUT ADMITTING OR DENYING THE
FINDINGS, EXCEPT AS TO ENTRY OF THE INJUNCTION AND THE SEC'S
JURISDICTION, WHICH ARE ADMITTED, SHORT CONSENTS TO THIS
ORDER. THE SEC FINDS THAT: (1) FROM APPROXIMATELY APRIL 1999 TO
JUNE 1999, SHORT WAS ACTING AS AN UNREGISTERED BROKER-DEALER.
(2) ON 10/15/1999, THE SEC FILED A COMPLAINT IN THE U.S. DISTRICT
COURT FOR THE SOUTHERN DISTRICT OF NEW YORK AGAINST SHORT.
ON 10/18/1999, THE ACTION WAS TRANSFERRED TO THE NORTHERN
DISTRICT OF ILLINOIS [CASE #99 C 6895]. ON 6/1/2000, THE SEC FILED
AMENDED COMPLAINT. (3) THE SEC ALLEGES THAT FROM APRIL 1999
THROUGH JUNE 1999, SHORT VIOLATED THE FEDERAL SECURITIES LAWS
BY FRAUDULENTLY ENGAGING IN A $314 MILLION PONZI SCHEME
INVOLVING AT LEAST 1000 INVESTORS. THE SEC ALLEGES THAT SHORT
OFFERED AND SOLD SECURITIES IN THE FORM OF PROMISSORY NOTES
AND BONDS ISSUED BY A COMPANY, WHICH PURPORTED TO PROVIDE
RETURNS THROUGH INVESTMENTS IN THE CAR TITLE AND PAYDAY LOAN
BUSINESS. THE SEC ALLEGES SHORT RAISED $487,000. THE SEC ALSO
ALLEGES THAT THE INVESTMENT FUNDS WERE NOT USED IN THE CAR
TITLE OR PAYDAY LOAN BUSINESS, BUT RATHER WERE USED TO MAKE
INTEREST PAYMENTS TO EXISTING INVESTORS, TO PAY MARKETER
COMMISSIONS, AND FOR PERSONAL USE. THE SEC ALLEGES THAT
SHORT MADE MISREPRESENTATIONS AND OMISSIONS OF MATERIAL
FACT CONCERNING THE USE OF INVESTOR FUNDS AND FAILED TO
DISCLOSE THE SOURCE OF THE INTEREST PAYMENTS AND THAT THE
NOTES AND RECEIVABLES PURPORTEDLY SECURING CERTAIN
OFFERINGS WERE INSUFFICIENT SECURITY. THE SEC FURTHER ALLEGES
THAT SHORT, IN THE COURSE OF MARKETING THE SECURITIES, ACTED
AS AN UNREGISTERED BROKER-DEALER. ON 3/8/2000, THE COURT
ENTERED AN ORDER ENJOINING SHORT FROM VIOLATIONS OF SEC. 17(A)
OF THE SECURITIES ACT OF 1933 AND SECS. 10(B), 15(A), AND 15(C) OF
THE EXCHANGE ACT AND RULES 10B-5 AND 15C1-2 PROMULGATED
THEREUNDER. SHORT, WITHOUT ADMITTING OR DENYING THE
ALLEGATIONS CONSENTED TO THE ORDER.