....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.