....inaccurate public disclosure ....unlawful distribution of securities ....falsely recognizing revenue ....overstated BIELs revenue by $366,000, or 47%. ....engaged in an illegal distribution of unrestricted securities ....unregistered transactions at a discount ....orchestrated the illegal distribution. ....half of the proceeds .....was retained by the entities ....offerings were not registered with the Commission. ....constitutes improper professional conduct.
remedial action is appropriate in the public interest ...... including, but not limited to, a censure, disgorgement, a civil penalty and a penny stock suspension or bar.... should be ordered to pay disgorgement pursuant....