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The SEC charged that defendants, acting as unregistered broker- dealers and investment advisers, offered and sold to investors membership shares in at least ten Limited Liability Corporations under their control. They allegedly raised at least $24.5 million from approximately 120 investors in at least twelve states, which proceeds were supposed to be used to purchase securities sold by LLCs managed by BCI Aircraft Leasing (itself a fraud). However, defendants allegedly misappropriated least $5.4 million. They were administratively barred, among other consequences.