Securities Administrative Orders Issued

Securities Administrative Orders Issued 2017

The following orders were issued by the Division to enforce various provisions of the Wisconsin Uniform Securities Law as found in Chapter 551. Signed copies of Petitions for Order and Orders associated with the following persons or entities are available in the PDF format.

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Andrew Schneider and Unity Financial, LLC - Case No. S-236130 (EX) – Consent Orders Revoking and Permanently Barring Investment Adviser and Investment Adviser Representative Registrations were issued against Andrew Schneider and Unity Financial, LLC for the following violations:

Andrew Schneider and Unity Financial, LLC violated Wis. Stat. § 551.412(4)(m) and § DFI Sec. 5.06(4), Wis. Admin. Code when they engaged in dishonest and unethical practices by recommending that an investment advisory client invest in Alter Bee, a company owned and controlled by Schneider, without reasonable grounds to believe that the recommendation was suitable for the client on the basis of information furnished by the client after reasonable inquiry concerning the client's investment objectives, financial situation and needs, and any other information known to them.
Andrew Schneider violated Wis. Stat. § 551.412(4)(m) and § DFI Sec. 5.06(6), Wis. Admin. Code when he engaged in dishonest and ethical practices by borrowing money from an investment advisory client.

Orders issued on December 7, 2017.

Andrew Schneider, Unity Financial, LLC, Order

Option King a/k/a Advanced Option Capital, Greymountain Management, LTD, a/k/a Grey Mountain Management, David Cartu, and Duncan Adams - Case No. S-235236 (EX) – Summary Cease and Desist Orders were issued against Option King a/k/a Advanced Option Capital, Greymountain Management, LTD, a/k/a Grey Mountain Management, David Cartu, and Duncan Adams for the following violations:

Option King, through its website purported to provide a binary options trading platform to the public, including Wisconsin residents.
Greymountain provided electronic support services for Option King’s website including but not limited to credit card processing services for binary options trading.
The Option King binary option contracts were investment contracts under Ch. 551, Stats., the Wisconsin Uniform Securities Law, because they constituted an investment in a common enterprise with the expectation of profits to be derived through the essential managerial efforts of someone other than the investor.
The Option King binary option investment contracts were never registered for offer and sale in Wisconsin pursuant to the Wisconsin Uniform Securities Law.
At no time was Option King, Greymountain, David Cartu, or Duncan Adams registered with the Division in any capacity, nor with a federal securities regulator.

Orders issued on November 27, 2017.

Option King a/k/a Advanced Option Capital, Greymountain Management, LTD, a/k/a Grey Mountain Management, David Cartu, and Duncan Adams, Order

MFB Investments, LLC, Malorie F. Berceau, Travis J. Ebert and Martin P. Berceau - Case No. S-235728 (EX) – Summary Cease and Desist Orders and Notices of Orders for Restitution and Civil Penalties were issued against MFB Investments, LLC, Malorie F. Berceau, Travis J. Ebert, and Martin P. Berceau for the following violations:

MFB Investments, LLC and Malorie F. Berceau violated Wis. Stat. § 551.403(1) by transacting business as an investment adviser in Wisconsin without being registered under Ch. 551 or exempted from registration under Wis. Stat. § 551.403(2).
MFB Investments, LLC and Malorie F. Berceau violated Wis. Stat. § 551.502(1)(a) when, in the course of advising others for compensation, either directly or indirectly, as to the value of securities or the advisability of investing in, purchasing, or selling securities, they employed a device, scheme, or artifice to defraud another person.
MFB Investments, LLC and Malorie F. Berceau violated Wis. Stat. § 551.502(1)(b) when, in the course of advising others for compensation, either directly or indirectly, as to the value of securities or the advisability of investing in, purchasing, or selling securities, engaged in an act, practice, or course of business that operated or would operate as a fraud or deceit upon another person.
MFB Investments, LLC, Malorie F. Berceau, and Travis J. Ebert violated Wis. Stat. § 551.501(2) when, in connection with the offer, sale, or purchase of securities, they made untrue statements of material fact and omitted to state material facts necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading.
MFB Investments, LLC, Malorie F. Berceau, and Travis J. Ebert violated Wis. Stat. § 551.501(3) when, in connection with the offer, sale, or purchase of securities, they engaged in an act, practice, or course of business that operates or would operate as a fraud or deceit upon another person.
Martin P. Berceau violated Wis. Stat. § 551.501(3) when, in connection with the offer, sale, or purchase of securities, he engaged in an act, practice, or course of business that operates or would operate as a fraud or deceit upon another person.
In the alternative, Martin P. Berceau materially aided and abetted the violations of Wis. Stat. § 551.501(2) by MFB Investments, Berceau and Ebert.

Order issued on October 27, 2017.

On November 27, 2017, the Respondents timely petitioned for a hearing. The Division and the Respondents entered into consent orders on April 6, 2018. Please refer to the 2018 orders section to view the consent orders and payment agreements resolving this matter.

Atlantis Health Group, LLC and Syed Mohammed Ali Karim - Case No. S-233706 (EX) – A Consent Cease and Desist Order was issued against Atlantis Health Group, LLC ("Atlantis Health Group") and Syed Mohammed Ali Karim ("Karim") (collectively "Respondents") for the following violations:

The Respondents violated Wis. Stat. § 551.301 when they sold a promissory note to a Wisconsin resident which was not a federally covered security, or registered or exempted from registration under Ch. 551.
The Respondents violated Wis. Stat. § 551.501(2) when they, in connection with the offer and sale of a security, made untrue statements of material fact, including the misrepresentation that Atlantis Health Group earned an annual revenue of $70,000,000 when in fact it was never profitable, and the misrepresentation that a Wisconsin investors funds would be used for the business of Atlantis Health Group when in fact it was immediately used for the personal expenses and pre-existing debt of Karim.
The Respondents violated Wis. Stat. § 551.501(2), when they, in connection with the offer and sale of a security, omitted to state material facts necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading, including the financial condition of Atlantis Health Group in 2014 and 2015 when Karim solicited a Wisconsin investor to reinvest in the company.

Order issued on October 12, 2017.

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