- Steele Financial and Tamara Steele sold $15mn in stock from a private company,
Behavioral Recognition Systems (BRS), previously charged with fraud by the SEC.
- Shares sold to 120 advisory clients, many of whom are current or former teachers.
- Steele did not disclose that she and the firm would receive up to 18% from sales.
- Lead to total commission of cash and warrants from BRS that were worth $2.5mn.
- False invoices were created to conceal involvement with the sale of BRS securities.
- SEC sought disgorgement of ill-gotten gains with interest, penalty and injunctions.