A. This matter involves an employee of an investor relations firm, who touted stock on an Internet bulletin board without disclosing that he was being compensated for the posts by his employer. This employee, the respondent in this proceeding, failed to disclose that he was promised thousands of shares of stock as a bonus for assisting his employer in promoting the stock of Snelling Travel, Inc. ("SNLV"), which is quoted on the over-the-counter bulletin board. The respondent's failure to disclose this remuneration was fraudulent, and in violation of Section 17(b) of the Securities Act, which makes it unlawful for any person to tout stocks for consideration without fully disclosing the consideration.
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