The pair is also accused of selling unregistered securities without exemption from the SEC, and acting as unregistered brokers in the Turnkey Investment Fund securities by soliciting investors and earning transaction-based compensation as a result of their sales.

In a 12-count claim for relief, the SEC charges each defendant with individual counts of fraud and multiple violations of the Exchange Act, Securities Act and Advisers Act, seeking injunctions from further violations, disgorgement of ill-gotten gains with pre-judgment interest, civil penalties, and a conduct-based injunction against Fossum.
 

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