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Respondent Sarris, Sr., a registered investment adviser, through his company Sarris Financial Group, allegedly convinced over 70 individuals to invest over $30 million in private funds that purportedly traded in foreign currencies called the “Kenzie Funds.” The Kenzie Funds, however, actually were a massive Ponzi scheme that defrauded at least 400 investors out of more than $105 million. Defendants allegedly misrepresented their relationship with the Kenzie Funds, which paid them incentive fees, did not investigate and ignore red flags, and even proposed that they use existing or new investor money to pay redemptions to departing investors (i.e., Ponzi payments), twice.