The first of several securities fraud complaints was filed today against RML, Luther Parker, Larry Ohm CPA, Joe Thomas and all “board members” of Ridge Management Ltd, Inc.

This first complaint for securities law violations was filed with the State of Tennessee Department of Commerce and Insurance Securities Division in Nashville.  Below you can see the completed form.  Attached to the form was the following information along with an included CD-ROM that provides copies of nearly 300 pages of applicable documents and evidence.

Since the current ownership of all 84 units at Deer Ridge Mountain Resort include domiciles in 19 states, I intend to file similar complaints for securities fraud, and other securities law violations, with each of those additional 18 individual states securities divisions.  Additionally, since four of the five board members live outside of Tennessee and since ownership is spread across 19 states, I intend to file a similar complaint for securities fraud and other securities law violations with the Securities Exchange Commission (SEC) in Washington D.C. since the geographically diverse ownership makes it a federal case. (Note: If an owner’s home address is in any particular state, then almost always, that state’s unique and specific securities laws must also be followed to the letter – as well as the securities laws of the state of Tennessee.)

As I have previously mentioned here, Luther Parker, Larry Ohm and Joe Thomas all have continued to falsely represent that RML makes money and does not cost our GGRC HOA and the Deer Ridge owners money.  In spite of me showing my proof that RML has lost us $2 million during the past 16.5 years BASED ON THEIR AUDITS, the Gang of Six refuses to admit their lies.

I have asked Luther Parker for his proof of his statements in his November 15, 2011 letter that was sent to all owners, “RML does not cost the HOA. In the past it funded GGRC approximately $45,000 per year.  The cost to operate GGRC remains the same with or without RML. HOA fees would not be cut in half.”

Folks, these statements by Luther Parker are lies.

And I am tired of Luther Parker, Larry Ohm CPA, Joe Thomas, David Barone, Tom Reise and Margie Duncan intentionally misleading all owners regarding this hugely important and pivotal matter.  Luther has not come forward with any proof. So, I intend to force him to prove his statements were true to state authorities – in lots of states.

Based on my experience gained from starting and owning my own National Association of Securities Dealers (NASD) broker-dealer corporation and being a member of the Securities Investor Protection Corporation (SPIC), and having raised $25 million from investors and venture capital, I know something about state and federal securities laws.  And it is my opinion,  based on all of that experience, that these kinds of lies told repeatedly by Luther Parker, Larry Ohm CPA, Joe Thomas, David Barone, Tom Reise and Margie Duncan should be considered securities fraud.

Additionally, since buying any condo at Deer Ridge requires that any owner become a de facto stockholder of RML, at least 40% of all owners’ HOA fees will be squandered by feeding RML’s massive negative cash flow. Since every new owner, along with all existing owners, are forced to fund this ongoing need for capital contributions into the illegitimate RML, I believe that additional, ongoing major securities fraud is committed by Joe Thomas every time he sells a condo.

This is because Joe Thomas NEVER tells buyers they will be forced to own part of RML and fund these huge negative cash flows. I believe that this despicable and intentional lack of disclosure by Joe Thomas probably violates multiple other state and federal securities laws as well as being violations of the rules and regulations of the Tennessee Real Estate Commission.

RML Is A Corporation That Issued Shares And Is Required To Abide By Securities Law

Whether the Gang of Six likes it or not, Ridge Management Ltd, Inc. is a corporation that is governed by securities laws in Tennessee and elsewhere. As such, these securities laws regulate what can be done, how it can be done and what can be said or not said with regard to RML.

One of the things officers and directors cannot do is lie and mislead investors in the corporation.

If I am showing, based on the corporation’s own audits, that RML lost $2 million during the past 16.5 years, you can easily verify my statement and my math by reviewing the same audits.  The same is true for the Securities Division of Tennessee, and all other securities agencies and the SEC.

Luther Parker made his above statements about a month ago.  I’ve asked him to prove it.  He has chosen once again to ignore owners’ demands of proof – and has not provided an iota of proof of his statement.  Again, this is Luther Parker’s most recent published lie, “RML does not cost the HOA. In the past it funded GGRC approximately $45,000 per year.  The cost to operate GGRC remains the same with or without RML. HOA fees would not be cut in half.”

Uh huh.

Now, he can try to prove every nuance of those statements to the Securities Division of Tennessee.  And, they won’t take his empty, arm waving and name calling as proof of anything!  Plus, they have their own forensic accountants and forensic computer experts who know how to find malfeasance and ferret out the REAL truth.

Better get ready, boys, they are from the government – and they are here to help you!

Securities Division of Tennessee – An Agency With Big Teeth

Just so you know, the Securities Division of Tennessee is not some toothless state agency without power to force compliance.  Actually, it is just the opposite.  It can fine both the corporation and/or the individuals associated with the corporation for all sorts of securities law violations.

A review of recent actions taken by the Securities Division of Tennessee shows that they have forced consent decrees, taken away licenses, shut down companies and have fined individuals involved with various securities law violations, including securities fraud, with personal fines exceeding $500,000 for EACH person involved and for EACH violation.  These are for civil violations.  If they uncover criminal violations, those charges and actions are dealt with separately and IN ADDITION to the punishments and fines for civil violations.

I would call that some major teeth, n’cest pas?

Just The Start

Virtually every state has a securities division or agency similar to the Securities Division of Tennessee.  And each one has similar kinds of teeth for similar kinds of securities fraud.

Of course, if you think that’s bad – well, then we also have the Securities Exchange Commission to help us out since Deer Ridge and RML fall under federal scrutiny too.  The SEC has monster teeth.

These are the same folks that sent Martha Stewart and Bearnie Madoff to prison after charging them with securities fraud and other securities law violations. The SEC has already charged 87 CEOs, CFOs and other senior officers and their banks and mortgage companies in the 2008 Financial Crisis with securities violations and have already fined these officers and directors with nearly $2 billion in penalties, disgorgement and other monetary relief.

The Word of Today For The Gang of Six: Disgorgement

Disgorgement is repayment of ill-gotten gains that is imposed on wrong-doers by the courts. Funds that were received through illegal or unethical business transactions such as securities law violations are disgorged, or paid back, with interest to those affected by the action.

Individuals or companies that violate Securities and Exchange Commission (SEC) regulations are typically required to pay both civil money penalties and disgorgement. Civil money penalties are punitive, while disgorgement is about paying back profits made from those actions that violated the SEC’s regulations. However, disgorgement payments are not only demanded of those who violate securities regulations. Anyone profiting from illegal or unethical activities may be civilly required to disgorge their profits.

My expectation is that the SEC and the various state securities agencies will take this same approach of disgorgement with regard to the $2 million Luther Parker lie, and all the OTHER lies and misrepresentations, and force this kind of repayment to ALL past and current owners at Deer Ridge. (Yes, folks, even those of you who have already sold your unit or lost it in foreclosure or forced to sell at a loss may be covered by the complaint process – so be sure and file your own complaint!  See below.)

Based on everything I know about securities law – and the MANY ways that things are wrongly done at Deer Ridge and the way lies have been told for years along with all the massive, misleading misrepresentations – I think the SEC might find it interesting to research ALL the ways that this fiefdom has been run for so many years – and the millions of dollars it has cost past and current owners.

Allegations

Remember, as of now these are just my allegations of securities wrong doing by Luther Parker, Larry Ohm CPA, Joe Thomas, David Barone, Tom Reise and Margie Duncan.  I believe that I am 100% correct on these allegations based on my years of experience in the business.  We will have to wait and see if any, or all, of the 19 states and/or the SEC agree with me.

Below the line is what I filed with the official complaint form for the Securities Division of Tennessee.  If you would like to file your own securities law violations complaint against RML and/or the individual members of the Gang of Six with the Tennessee Securities Division, just click “Book ‘em Danno!”

Note:  It costs you nothing to file a securities law complaint against RML and the Gang of Six.   The great State of Tennessee will take care of it all for you, start to finish, without you having to spend a penny.  The same is true for the SEC – and probably every one of the other 18 states where Deer Ridge owners live.

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Investor Complaint For Securities Fraud And Other Securities Law Violations Filed Against Ridge Management LTD, Inc.
and
President Luther Parker, Treasurer Larry Ohm CPA, General Manager Joe Thomas, Vice President Tom Reise,  Secretary David Barone and Director Margie Duncan

Summary

Ridge Management Ltd, Inc. (“RML”) is a “for profit” Tennessee domestic corporation, with corporate offices at 3710 Weber Road, Gatlinburg, Tennessee 37738, and was originally incorporated December 29 1987.  A copy of the current filing information (Control #198618), incorporation documents, stock certificate and articles of incorporation are included as Exhibit A.  (All supporting documents are in Acrobat format and are contained in the included CD-ROM.)

RML is owned by the 84 owners who own individual condominiums at Deer Ridge Mountain Resort, Gatlinburg, Tennessee, which is governed by the Gatlinburg Golf and Racquet Club Condominium Association, Inc. (“GGRC”) in accordance with the Tennessee Horizontal Property Act.  GGRC is a “non-profit” Tennessee domestic corporation with corporate offices at 3710 Weber Road, Gatlinburg, Tennessee 37738, and was originally incorporated March 13, 1984. A copy of the current filing information (Control # 139212) is also included in Exhibit A.

Luther Parker, of Memphis, Tennessee, serves as the President of both GGRC and RML.

Many, if not most, owners of the 84 total outstanding shares of RML are believed to be unaccredited and unsophisticated investors.  The prices for condos at Deer Ridge generally range from $35,000 to $90,000.

RML is a rental company that provides motel services for certain Deer Ridge owners, and other real estate owners who do not own a Deer Ridge unit, who wish to rent their individual condo or cabin.  Only about 60 of the 84 units at Deer Ridge currently use the motel services of RML.  The other 24 owners do not rent their condo or use another rental management company.  It is important to note that RML is not solely focused on providing motel services to Deer Ridge owners – but is, instead, a motel service that aggressively pursues cabins and other rental properties which are completely unaffiliated with Deer Ridge.  However, in spite of RML expending up to $100,000 and more each year in advertising and marketing, this high risk small company has not been successful in competing in the motel business marketplace and has only signed up about a half dozen additional rental properties.

As a consequence, based on corporate audits, RML has lost $2 million during the past 16.5 years.  As the following will show, this $2 million loss was funded by illegitimate capital calls.

By way of background, for the past six plus years, I have been an owner of one of the 84 condo units governed by GGRC.  As such, I am one of the 84 de facto shareholders of RML.

As an MBA, and the founder and past owner of a NASD Broker/Dealer company which was also a member of SIPC, I believe that I have the necessary credentials and background to recognize that RML has committed, and continues to commit, what I believe are major state and federal securities law violations including securities fraud exceeding $2 million.

I believe that many of these violations may include current criminal conduct as well as blatant civil violations including ongoing securities fraud happening on a monthly basis.

It is my contention that these securities law violations, which have been going on for more than two decades, have already resulted in many past and current stockholders being forced into personal bankruptcy and/or losing their Deer Ridge condo in foreclosure or have been forced to sell their unit at a significant loss.

Currently, the owners of the 84 units at Deer Ridge are comprised of approximately 14 owners who live in Tennessee and 70 who have domicile addresses in 18 other states.

As such, since securities laws for other jurisdictions are clearly involved, we intend on contacting the state agency for securities laws in each of those 18 other states as well as the Securities Exchange Commission in Washington D.C. for issues regarding federal law.  We intend on sending those agencies this same information in this letter along with a copy of the enclosed CD-ROM that contains the supporting documents and evidence.

However, since I am a born and raised Tennessee resident, and since the corporations involved are domestic and under your jurisdiction, I wanted to first contact your department regarding these securities violations so that you could have a head start on enforcement and compliance.

As such, I respectfully request that the Securities Division of the Department of Commerce and Insurance for the State of Tennessee thoroughly investigate this complaint for the protection of the past, current and future owners of common stock in RML.

Investor Complaints

My investor complaint includes the following allegations:

1. Luther Parker, President of both GGRC and RML, continues to perpetrate a fraud on all stockholders by fraudulently claiming, as recently as 30 days ago, that RML has continually made money for the owners.  Please see Exhibit B, Luther Parker Letter, dated November 15, 2011 and mailed to all Deer Ridge owners on or about December 1, 2011.
2. In spite of the fraudulent claims by Luther Parker, CPA audits commissioned by the corporation clearly show that RML has lost nearly $2 million of investors’ money during the past 16.5 years.  This loss of $1,915,934 is calculated based on CPA audits completed by Hickman and Company, CPAs under the direction of Luther Parker, President, Larry Ohm, CPA and Treasurer and Joe Thomas, General Manager.  Please see Exhibit C for copies of all audits and a comprehensive analysis of the audited numbers.
3. This RML loss of $1,915,934 over the past 16.5 years equates to an average RML loss of $116,117 every year.
4. This annual average RML loss of $116,117 is funded directly out of the pockets of all 84 Deer Ridge owners under the guise of increased monthly HOA fees to all condo owners at Deer Ridge who happen to also be the stock holders of RML.  Instead of the required capital for the operating deficit being funded by an optional capital call to all stockholders, the needed funds are fraudulently included in the monthly HOA fees that are required of all owners.  These hidden equity payments continue to equal more than 40% of the contrived monthly HOA fee.  Please see Exhibit D for a list of all current stockholders.
5. This annual average RML loss of $116,117 equals 40% of the $290,540 annual HOA fees collected from all owners of the 84 units at Deer Ridge.  As a consequence, nearly half of all HOA fees paid in by the mostly unaccredited and unsophisticated investors are being squandered by this illegitimate corporation’s need for monthly capital infusions.
6. I contend that the actual RML losses are, in fact, much higher than the annual average RML loss of $116,117 shown on the audits.  This is because the audits indicate various expense items that should rightfully be associated with and cost accounted with the motel operation of RML are, instead, spurious costs that are listed as expenses of GGRC.  I believe that this is being done in order to intentionally deceive stockholders as to the actual losses that accrue each year from RML’s unprofitable motel operation.
7. RML was illegitimately formed by the board of directors of GGRC in 1987 without a vote of owners – and without providing owners any kind of disclosure or offering document that detailed the risks, management compensation, etc. of the unregistered security.  In spite of it not being an approved Common Expense of GGRC, funding for this new corporation, RML, was pulled from the general operating account of GGRC, a non-profit corporation, which in turn was, and is, fully funded by the 84 owners of the condos at Deer Ridge Mountain Resort.  As such, RML has offered and continues to offer, unregistered securities to Tennessee residents along with residents of at least 18 other states. Please see Exhibit D.
8. Under the Securities Act of 1933, it is against the law for any company, or “issuer,” to sell securities without either registering the securities with the Securities and Exchange Commission pursuant to Section 5 of the Securities Act or relying upon a valid exemption from the registration requirements. Similarly, pursuant to each individual state’s “Blue Sky” laws, it is generally against the law to sell securities within a state without either registering the securities with the state’s securities regulatory agency or relying upon a valid state exemption from registration.
9. At no time has RML or GGRC ever issued any kind of Reg D private placement memorandum or any other offering document or any type of disclosure documents to the stockholders of RML.  There has never been any discussion of risk factors, management compensation or limitations of transfer of ownership that could have tax consequences to both the stockholders and the corporation.  Additionally, no investors were ever asked to complete any prospective purchaser questionnaires that asserted that they were accredited.  Additionally, no Form D was filed with either the state of Tennessee or with the SEC in Washington, D.C. nor was there any filing fee paid in Tennessee for RML or GGRC to qualify for any securities exemptions.  As a consequence, any securities offering made by RML or GGRC does not qualify for any exemptions contemplated by Tenn. Code. Ann. §48-2-103.
10. TENN. CODE ANN. § 48-2-102 provides that a security is defined to include investment contracts. An investment contract is an agreement wherein initial value is given and subjected to the risks of an enterprise, with a valuable benefit of some kind, over and above the initial value, being promised, but the investor does not receive meaningful rights to exercise practical or actual control over the managerial decisions of the enterprise. I believe that this definition of an investment contract includes an investment in a vacation home.  Please note from Joe Thomas’ current Real Estate Sales Package that is available to the general public, shown as Exhibit E, that he sells condos at Deer Ridge Mountain Resort as a “personal or corporate investment.”  Joe Thomas is also currently advertising these investments in the mainstream media, thereby, in my opinion, publicly offering unregistered securities to Tennessee residents and engaging in securities fraud.
11. In examining Exhibit E, “Joe Thomas Deer Ridge Sales Package, December 2011,” note the following reference: “GG&RC HOA Fees cover maintenance and upkeep of all commonly owned areas including but not limited to exterior lighting, parking lot, landscaping, playground, tennis court, picnic pavilion, recreation building including indoor pool, Jacuzzi, sauna, steam room, game room, offices, golf membership and multi-peril insurance on the same.” In spite of Joe Thomas’ insider knowledge and review of the annual audits, nowhere in his “disclosure” is any reference to the fact that 40% or more of the HOA fees listed are used to fund the average annual operating deficit of $116,117 of RML based on the corporation’s audits.  As a consequence, buyers of condos at Deer Ridge are never told of this ongoing capital call requirement, and major risk factor, prior to their purchase of a condo.
12. Buyers and owners of condos at Deer Ridge are given no choice of owning shares of RML.  All owners must own a share of RML and are required to fund RML’s large operating deficits under the guise of required HOA fees that are nearly twice what would be required if RML were not funded by HOA fees.  If owners object to this ongoing monthly capital call and do not pay, those owners are threatened with foreclosure of their home at Deer Ridge.  This includes the 24 owners who do not use RML’s services – many of whom object to this illegitimately required monthly capital call funding into RML.
13. Additionally, there continues to be a complete lack of any disclosure whatsoever regarding the required, ongoing, monthly capital call funding for RML’s negative cash flow when a new owner purchases a condo at Deer Ridge.  For example, when I bought my unit, Joe Thomas acted as both listing and selling broker on the transaction.  At no time did Joe Thomas disclose any requirement for us to own a participating share of RML nor did he disclose that nearly half of the property’s annual HOA fees would be used to support a motel management company’s negative cash flow – even if we were not users of RML’s motel services.  It is our understanding from recent property sales that Joe Thomas continues his historical lack of disclosure.
14. The fact that Joe Thomas also served then, and continues to serve, as General Manager of both GGRC and RML, as well as the principal broker of Ridge Resort Realty (a DBA of RML), gave and gives him complete knowledge and insights into the true operation of both corporations.  As such, I contend that Joe Thomas knowingly and deviously omits this disclosure as part of his deceptive trade practices as a real estate agent since many buyers, ourselves included, would have never bought a Deer Ridge condo if proper disclosure of this risk factor had been properly made.
15. It is my contention that most buyers of small condos under $90,000 do not expect that they will also be unwilling stockholders in a money-losing motel business that will squander almost half of each year’s HOA fees.  As such, the lack of this disclosure by broker and General Manager Joe Thomas is especially nefarious and fraudulent.
16. It is my contention that Luther Parker, president, is aided and abetted by all four other members of the board of directors and the company’s general manager, all of whom are co-conspirators in securities fraud and other securities law violations and have breached their fiduciary duties to all stockholders.  The board members are President Luther Parker of Memphis, TN,  Vice President Thomas Reise of Friendship, WI, Treasurer Larry Ohm, CPA of Grant Park, IL, Secretary David A. Barone of Monroe, NY and Director Margie Duncan of Florence, KY.  General Manager of RML is Joseph Thomas of Kodak, TN.  Please see Exhibit F for a complete listing including each individual’s home address, home telephone number and personal email address.
17. It is my contention that all five board members and Joe Thomas have conspired for years to fraudulently deceive owners at Deer Ridge regarding the profits and losses of RML in order for them to continue to operate their motel business for their own personal gain and benefits – none of which are disclosed to owners.  These six individuals are concerned about the growing complaints of owners regarding having the highest HOA fees in the entire East Tennessee area.  These six individuals are concerned that if the owners knew the truth about more than 40% of the HOA fees were used to cover the exorbitant losses of RML, these owners would take action to shut down this illegitimate corporation and cut their HOA fees in half.  These six individuals are concerned that with an RML shut down, the benefits they uniquely receive from their motel business would be lost.  I contend that this is the primary reason that Luther Parker, Larry Ohm, CPA and Joe Thomas lead this conspiracy to fraudulently lie to all owners about the profitability of RML.
18. TENN. CODE ANN. § 48-2-121 provides that it is unlawful for any person, in connection with the offer, sale or purchase of any security in this state, directly or indirectly, to make any untrue statement of a material fact or omit to state a material fact necessary in order to make the statements made, in light of the circumstances under which they are made, not misleading.  In spite of the corporations’ audits showing a $2 million loss during the past 16.5 years, Luther Parker, Larry Ohm and Joe Thomas continue to falsely assert that RML is a profitable operation in order to intentionally mislead stockholders.
19. Additionally, those who choose to not use RML’s motel services, such as 24 current owners,  are subjected to significant discrimination, retaliatory actions and malicious slander and libel as well as being burdened with financial costs not borne by RML participants.
20. Many of these same board members and Joe Thomas have been in complete control of the board and the operation of Deer Ridge for a decade or more.
21. The company’s treasurer is Larry Ohm who claims to be a CPA in Illinois.  I contend that because of his profession-required understanding of financial statements, Larry Ohm fully understands the audits and the nearly $2 million aggregate loss they show for the past 16.5 years.  Yet, he continually and fraudulently misrepresents that RML is making the stockholders money.  Please see Exhibit G which clearly shows Larry Ohm falsely stating that, “This clearly contradicts the accusations by anyone that HOA fees and special assessments are being utilized to pay for the costs of operating RML. In truth, in the past, it was RML that was providing a subsidy to GGRC.” This fraudulent and misleading statement by Larry Ohm, CPA, was made to all owners in spite of 16 years of audits of the corporation clearly showing a $2 million loss, or an average loss of $116,117 every year for 16 years!
22. Exhibit H includes my Warranty Deed, complete closing statement package and my fully executed purchase contract with all attachments showing Joe Thomas as the only broker involved.  These documents show that there was never any disclosure of any kind made to me prior to closing that indicate in any way that I would be fraudulently forced to support a money losing corporation such as RML as part of my purchase or a residential condo.  Again, if this had been properly and legitimately disclosed, I would have never considered closing on this transaction.
23. During the past six plus years that I have owned a condo at Deer Ridge, I have documentation that repeatedly pointed out to these board members that they are lying to the owners about RML’s profitability in light of the attached annual audits that they themselves commission each year.  Therefore, there can be no legitimate claim by any board member or General Manager Joe Thomas that they had no knowledge of the facts.
24. In spite of numerous attempts, during the past six plus years that I have owned a condo at Deer Ridge, I have never received a copy of the Administrator’s Book that lists all income and disbursements, along with supporting vouchers.  This Administrator’s Book, in this specific format, is required by the Tennessee Horizontal Property Act (§66-27 -113.) It is my understanding that Joe Thomas and the board have never made this Administrator’s Book available to any owner.  Ever.  As a consequence, no owner or stockholder in RML has ever been allowed to see the books and records as required by Tennessee state law.   It is my contention that this stonewalling is driven by the conspiring board’s strong desire to hide certain transactions from the scrutiny of the stockholders – and it is my belief that these hidden transactions hide multiple acts of malfeasance.

Again, based on my many years of experience from owning a NASD broker-dealer and my involvement with numerous private placement offerings and the applicable state and federal securities laws that control such offerings, I strongly believe there may be major, ongoing malfeasance that is negatively impacting the stockholders of RML.

The owners at Deer Ridge are mostly unaccredited investors who, in my opinion, are being consistently and deliberately deceived and victimized by a conspiracy by the board of directors of both RML and GGRC who are personally benefiting from these deceptions. I believe that these ongoing activities and material misrepresentations are violations of the Tennessee Securities Act of 1980, as amended, and put the public at significant risk of immediate and irreparable injury, loss or damage.

Based on the above allegations and the enclosed exhibits, I believe that your investigation will find that Joe Thomas, Luther Parker, Larry Ohm CPA and the rest of the board continue to perpetrate numerous and substantial securities law violations to the financial determent of past, current and future stockholders of RML.

I respectfully request that the Securities Division of the Department of Commerce and Insurance for the State of Tennessee investigate this complaint for the protection of the current and future owners of stock in RML.

I will be glad to be of help to your investigation.

Not only can I provide your department with numerous additional documents and evidence not contained on the enclosed CD-ROM, I will gladly meet with you at your convenience or discuss these allegations on the phone in order to expedite your review of the facts concerning the securities violations of Ridge Management Ltd, Inc. by its board of directors and general manager.

Thank you for your consideration of my complaint.

Sincerely,

Robert Goodman

PS:  Much of this legal fight is fully documented at my blog www.DeerRidgeOwners.com. This blog has between 35,000 and 50,000 page views per month – with interested viewers all over the country watching to see what justice can be found in the great State of Tennessee.

I hope that the actions of the Securities Division of the Department of Commerce and Insurance for the State of Tennessee will show the nation that we will not tolerate securities fraud and other securities law violations – and that even unaccredited and unsophisticated investors will be protected.

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Stay Tuned!

We live in interesting times.  And, hopefully, with the help of the State of Tennessee Securities Division, we will make 2012 VERY interesting for the Gang of Six!