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Magnum7419

11/07/17 1:04 PM

#237822 RE: greens12 #237819

Please point out anything inaccurate so I can respond.

Summary
1. From approximately January 2, 2013 to November 19, 2014 (“Relevant Period”),
Krueger, while associated with Canterbury Consulting, Inc. (“Canterbury”), improperly favored
himself over customers and clients when allocating trades (also known as “cherry-picking”).
Krueger executed his fraudulent cherry-picking scheme by purchasing and selling securities
through an omnibus trading account, which afforded him the ability to purchase large blocks of
securities that he then allocated to his customers and clients. Krueger, however, delayed allocating
the trades until he knew whether the trades had made a profit during the day. When a security
appreciated in value on the day of purchase, Krueger would often sell the security, creating a
profitable day trade. Krueger then disproportionately allocated the profitable day trades to his
personal accounts. In contrast, for securities that did not appreciate on the day of purchase,
Krueger would disproportionately allocate these purchases to his customers’ and clients’ accounts.
As a result of the scheme, Krueger realized $309,651 in ill-gotten gains, inclusive of commissions
and advisory fees earned from those he harmed.

Respondent
2. Kenneth P. Krueger, 74, resides in Newport Beach, California.


Respondent be, and hereby is:
barred from
association with any broker, dealer, investment adviser, municipal
securities dealer, municipal advisor, transfer agent, or nationally recognized
statistical rating organization;
prohibited from serving or acting as an employee, officer, director, member of an
advisory board, investment adviser or depositor of, or principal underwriter for, a
registered investment company or affiliated person of such investment adviser,
depositor, or principal underwriter; and
barred from participating in any offering of a penny stock, including: acting as a
promoter, finder, consultant, agent or other person who engages in activities with a
broker, dealer or issuer for purposes of the issuance or trading in any penny stock,
or inducing or attempting to induce the purchase or sale of any penny stock.

https://www.sec.gov/litigation/admin/2017/33-10430.pdf

NEWPORT BEACH, Calif., Nov. 3, 2015 /PRNewswire/ -- Terra Tech Corp. (OTCQX: TRTC) ("Terra Tech" or the "Company"), a vertically integrated cannabis-focused agriculture company, today announced the appointment of Kenneth P. Krueger to the Board of Directors.

Mr. Krueger has over 48 years of experience in the financial industry, having co-founded Canterbury Consulting in 1988 and served as its Chairman of the Board, Chief Financial Officer, and Head of Compliance. Canterbury Consulting is an investment office for foundations, endowments, healthcare organizations, religious organizations, and corporate plans, overseeing more than $14 billion in funds. Ken's experience in making strategic, financial, and capacity decisions to optimize investment return will be a positive addition to Terra Tech as it continues to execute on its growth strategy.

https://www.prnewswire.com/news-releases/terra-tech-corp-appoints-kenneth-p-krueger-to-board-of-directors-300170939.html