False statement that "They were legally acquired and documented. "
1. Years of notes were backdated
2. KW couldn't privide documentation to the SEC for her one-time and nominal investment.
3. The SEC stated that the notes were a product of self-dealing, and therefore "ill-gotten gains".
The issue remains current as the 6-figure fines reside on BIEL's balance sheet, and are nearly 1-year over due. Interest, fines, and penalties are accruing.