- 2016
- $277,254
The SEC found that respondent Todd acted as an unregistered investment adviser in raising $11,125,500 from approximately 150 investors during October 2010 through January 2012. Co-respondents were the investment vehicle and other controlled affiliates, which were improperly used as intermediaries for many of the fund’s business transactions (sales and purchases of oil and gas royalty interests), enabling $308,638 in disguised illicit profits to be funneled to Todd at the expense of the fund.
