With 506(c) now, can you imagine.
Take NewCo, Inc. (of Nevada) trading as NEWC, and some scammer sets up New Corp. Inc. (one that is not trading or filing with the SEC) in Wyoming. Sets up a bank account in Wyoming. Then starts cold calling from a boiler room and each caller represents themselves as the CEO of NewCo, the trading company.
Then investors send checks to Wyoming thinking they invested in the trading company. But the deposit went into the fraudulent boiler room operation's account.
After a month or two, the boiler room shuts down, and millions have already transacted.