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J.P. Morgan Sued For Edward Turley’s Alleged Misconduct: $55 Million!

The Law Offices of Robert Wayne Pearce, P.A. has filed another case against Ex-J.P. Morgan broker Ed Turley for alleged misrepresentations, misleading statements, unsuitable recommendations, and mismanagement of Claimants’ accounts. The Law Offices of Robert Wayne Pearce has filed another case against J.P. Morgan Securities for alleged misrepresentations, misleading statements, unsuitable recommendations, and mismanagement of Claimants’ accounts continuing in fall 2019 and thereafter by Edward Turley (“Turley”), a former “Vice-Chairman” of J.P. Morgan. At the outset, it is important for our readers to know that our clients’ allegations have not yet been proven. IMPORTANT: We are providing information about our clients’ allegations and seeking information from other investors who did business with J.P. Morgan and Mr. Turley and had similar investments, a similar investment strategy, and a similar bad experience to help us win our clients’ case. Please contact us online via our contact form or by giving us a ring at (800) 732-2889. Latest Updates on Ed Turley – November 18, 2022 The Advisor Hub reported today that the former star broker with J.P. Morgan Advisors in San Francisco Edward Turley agreed to an industry bar rather than cooperate with FINRA’s probe of numerous allegations of excessive and unauthorized trading that resulted in more than $100 million worth of customer complaints. FINRA had initiated its investigation of Edward Turley as it related to numerous customer complaints in 2020. The regulator noted in its Acceptance Waiver and Consent Agreement (AWC) that the investors had generally alleged “sales practice violations including improper exercise of discretion and unsuitable trading.” According to Edward Turley’s BrokerCheck report, he had been fired in August 2021 for “loss of confidence concerning adherence to firm policies and brokerage order handling requirements.” On October 28th, FINRA requested Turley provide on-the-record testimony related to his trading patterns, including the “use of foreign currency and margin, and the purchasing and selling of high-yield bonds and preferred stock,” but Edward Turley through counsel declined to do so. As a result, Edward Turley violated FINRA’s Rule 8210 requiring cooperation with enforcement probes, and its catch-all Rule 2010 requiring “high standards of commercial honor,” the regulator said and he was barred permanently from the securities industry. Related Read: Can You Sue a Financial Advisor or Stockbroker Over Losses? Turley Allegedly Misrepresented And Misled Claimants About His Investment Strategy The claims arise out of Turley’s “one-size-fits-all” fixed income credit spread investment strategy involving high-yield “junk” bonds, preferred stocks, exchange traded funds (“ETFs”), master limited partnerships (“MLPs”), and foreign bonds. Instead of purchasing those securities in ordinary margin accounts, Turley executed foreign currency transactions to raise capital and leverage clients’ accounts to earn undisclosed commissions. Turley over-leveraged and over-concentrated his best and biggest clients’ accounts, including Claimants’ accounts, in junk bonds, preferred stocks, and MLPs in the financial and energy sectors, which are notoriously illiquid and subject to sharp price declines when the financial markets become stressed as they did in March 2020. In the beginning and throughout the investment advisory relationship, Turley described his investment strategy to Claimants as one which would generate “equity returns with very low bond-type risk.” Turley and his partners also described the strategy to clients and prospects as one “which provided equity-like returns without equity-like risk.” J.P. Morgan supervisors even documented Turley’s description of the strategy as “creating portfolio with similar returns, but less volatility than an all-equity portfolio.” Note: It appears that no J.P. Morgan supervisor ever checked to see if the representations were true and if anybody did, they would have known Turley was lying and have directly participated in the scheme. The Claimants’ representative was also told Turley used leverage derived from selling foreign currencies, Yen and Euros, to get the “equity-like” returns he promised. Turley also told the investor not to be concerned because he “carefully” added leverage to enhance returns. According to Turley, the securities of the companies he invested in for clients “did not move up or down like the stock market,” so there was no need to worry about him using leverage in Claimants’ accounts and their cash would be available whenever it was needed. The Claimants’ representative was not the only client who heard this from Turley; that is, he did not own volatile stocks and not to worry about leverage. Turley did not discuss the amount of leverage he used in clients’ accounts, which ranged from 1:1 to 3:1, nor did Turley discuss the risks currency transactions added to the portfolio, margin calls or forced liquidations as a result of his investment strategy. After all, Turley knew he could get away without disclosing those risks. This was because J.P. Morgan suppressed any margin calls being sent to Turley’s clients and he liquidated securities on his own to meet those margin calls without alarming clients.  This “one-size-fits-all” strategy was a recipe for disaster. J.P. Morgan and Turley have both admitted that Turley’s investment strategy was not suitable for any investor whose liquid net worth was fully invested in the strategy. It was especially unsuitable for those customers like Claimants who had other plans for the funds in their J.P. Morgan accounts in fall 2019 and spring 2020. Unfortunately, Turley recommended and managed the “one-size-fits-all” strategy for his best clients and friends, including Claimants. Turley was Claimants’ investment advisor and portfolio manager and required under the law to serve them as a “fiduciary.” He breached his “fiduciary” duties in making misrepresentations, misleading statements, unsuitable recommendations, and mismanagement of Claimants’ accounts. The most egregious breach was his failure to take any action to protect his clients at the end of February 2020, when J.P. Morgan raised the red flags about COVID-19 and recommended defensive action be taken in clients’ accounts. Turley Allegedly Managed Claimants’ Accounts Without Written Discretionary Authority Claimants’ representative hired Turley to manage his “dry powder,” the cash in Claimants’ accounts at J.P. Morgan, which he would need on short notice when business opportunities arose. At one point, Claimants had over $100 million on deposit with J.P. Morgan. It was not...

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Investors With “Blown-Out” Securities-Backed Credit Line and Margin Accounts: How do You Recover Your Investment Losses?

If you are reading this article, we are guessing you had a bad experience recently in either a securities-backed line of credit (“SBL”) or margin account that suffered margin calls and was liquidated without notice, causing you to realize losses. Ordinarily, investors with margin calls receive 3 to 5 days to meet them; and if that happened, the value of the securities in your account might have increased within that period and the firm might have erased the margin call and might not have liquidated your account. If you are an investor who has experienced margin calls in the past, and that is your only complaint then, read no further because when you signed the account agreement with the brokerage firm you chose to do business with, you probably gave it the right to liquidate all of the securities in your account at any time without notice. On the other hand, if you are an investor with little experience or one with a modest financial condition who was talked into opening a securities-backed line of credit account without being advised of the true nature, mechanics, and/or risks of opening such an account, then you should call us now! Alternatively, if you are an investor who needed to withdraw money for a house or to pay for your taxes or child’s education but was talked into holding a risky or concentrated portfolio of stocks and/or junk bonds in a pledged collateral account for a credit-line or a margin account, then we can probably help you recover your investment losses as well. The key to a successful recovery of your investment loss is not to focus on the brokerage firm’s liquidation of the securities in your account without notice. Instead, the focus on your case should be on what you were told and whether the recommendation was suitable for you before you opened the account and suffered the liquidation.

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FINRA Arbitration: What To Expect And Why You Should Choose Our Law Firm

If you are reading this article, you are probably an investor who has lost a substantial amount of money, Googled “FINRA Arbitration Lawyer,” clicked on a number of attorney websites, and maybe even spoken with a so-called “Securities Arbitration Lawyer” who told you after a five minute telephone call that “you have a great case;” “you need to sign a retainer agreement on a ‘contingency fee’ basis;” and “you need to act now because the statute of limitations is going to run.”

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A Stockbroker’s Introduction to FINRA Examinations and Investigations

Brokers and financial advisors oftentimes do not understand what their responsibilities and obligations are and what may result from a Financial Industry Regulatory Authority (FINRA) examination or investigation. Many brokers do not even know the role that FINRA plays within the industry. This may be due to the fact that FINRA, a self-regulatory organization, is not a government entity and cannot sentence financial professionals to jail time for violation of industry rules and regulations. Nevertheless, all broker-dealers doing business with members of the public must register with FINRA. As registered members, broker-dealers, and the brokers working for them, have agreed to abide by industry rules and regulations, which include FINRA rules.

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UBS Financial Services, Inc. Sued for Florida and Ohio Advisor’s Alleged Misconduct Involving a Credit-Line Investment Strategy

UBS Financial Services, Inc, (“UBS”) employed a financial advisor (the “FA”) who has offices in Bonita Springs, Florida and Sylvania, Ohio. UBS held out the FA and other UBS employees on his team as investment advisers, investment managers, financial advisers, and financial planners with special skills and expertise in the management of securities portfolios and financial, estate, retirement, and tax planning matters.

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A Review of The Securities and Commodities Investment Laws

Financial Fraud Has Probably Been Around Since The Dawn Of Commerce. It Has Always Been Perpetrated By Individuals Who Scheme To Take Possessions (Goods And Capital) From Another By Misrepresentations, Misleading Statements, Manipulation And Other Means Declared Over Time To Be Fraudulent Practices, Schemes, Contrivances, And Devices.

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Oil and Gas Investors: How Do You Recover Your Oil and Gas Investment Losses?

Oil and Gas Investors: How Do You Recover Your Oil and Gas Investment Losses? If you are reading this article, we are guessing you invested in one or more of those misrepresented and unsuitable oil and gas stocks, bonds, limited partnerships, commodities, commodity pools and/or structured products as alternative investments linked to the oil and gas sector of the stock and commodities markets. We would not be surprised if you were told that the large oil and gas conglomerates had a proven track record of great dividends much higher than the yields on the fixed income investments you were accustomed but said nothing about the volatility of those types of investments. Maybe you are reading this webpage because your financial advisor recommended you invest your retirement savings in some those more complex and leveraged oil and gas structured products packaged as Exchange Traded Funds (ETFs), Exchange Traded Notes (ETNs) or other Exchange Traded Products (ETPs), that were leveraged two to three times and crashed in March this year. These were not suitable investments for retirees with conservative or moderate investor risk profiles. Did your financial advisor recommend you invest without explaining the nature, mechanics or risks of any of those oil and gas investments? Were your investments over-concentrated (more than 10% of your portfolio) by your stockbroker or investment advisor in the oil and gas sector to replace the bonds you owned for the higher dividend paying stocks? Did you lose fifty percent (50%) or more on those oil and gas investments? We’re not shocked because that is just what many other investors have told us about what happened to them recently. Now we are going to tell you what to do about those oil and gas investment losses. Your stockbroker had a duty to not only understand but explain the nature, mechanics and all of the risks associated with those investments before he/she sold you those investments, particularly some of the provisions within the ETNs where the broker-dealer who issued the ETNs or ETPs could redeem or retire them and force you to realize huge losses. Your stockbroker also had a duty to make sure they were suitable investments before they were recommended in light of your risk tolerance and financial condition and not over-concentrate investments in the volatile oil and gas sector in your portfolio. Unfortunately, many financial advisors who did not understand the nature, mechanics or risks sold these investments to clients with conservative and moderate risk who were seeking to enhance their income for their retirement. These were not suitable investments for investors with that kind of profile. If your financial advisor misrepresented the nature, mechanics or risks of those oil and gas investments or the risks were not fully explained, or you were over-concentrated (more than 10%) in the oil and gas sector, or if it was not in your best interest (or unsuitable), and/or your investments were liquidated without notice due to margin calls, you may have the right to bring an arbitration claim against your financial advisor and/or the brokerage firm who employed him. There is no way you will recover your losses on these oil and gas investments without some legal action. At The Law Offices of Robert Wayne Pearce, P.A., we represent investors in investment disputes for misrepresented and unsuitable investments in oil and gas stocks, bonds, limited partnerships, commodities, commodity pools and/or structured products as alternative investments linked to the oil and gas sector of the stock and commodities markets in FINRA arbitration and mediation proceedings. The claims we file are for fraud and misrepresentation, breach of fiduciary duty, failure to supervise, and unsuitable recommendations in violation of SEC and FINRA rules and industry standards. Attorney Pearce and his staff represent investors across the United States on a CONTINGENCY FEE basis which means you pay nothing – NO FEES-NO COSTS – unless we put money in your pocket after receiving a settlement or FINRA arbitration award. Se habla español CONTACT US FOR A FREE INITIAL CONSULTATION WITH EXPERIENCED STRUCTURED PRODUCT INVESTMENT ATTORNEYS IN FINRA ARBITRATIONS The Law Offices of Robert Wayne Pearce, P.A. have highly experienced lawyers who have successfully handled many oil and gas investment cases and other securities law matters and investment disputes in FINRA arbitration proceedings, and who work tirelessly to secure the best possible result for you and your case. For dedicated representation by an attorney with over 40 years of experience and success in structured product cases and all kinds of securities law and investment disputes, contact the firm by phone at 561-338-0037, toll free at 800-732-2889 or via e-mail.

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Regulation Best Interest (Reg. BI): Better But Not the Best!

Finally, ten years after the Dodd Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank) was enacted to bring about sweeping changes to the securities industry, the best regulation the U.S. Securities & Exchange Commission (“SEC”) could pass, SEC Regulation Best Interest, is now the law governing broker-dealers giving investment advice to retail customers. Although the SEC had the authority to impose a uniform and expansive “Fiduciary Duty” standard throughout the country upon broker-dealers and investment advisors, it yielded to the stock brokerage industry demands and enacted Regulation Best Interest (“Reg. BI”), which is better than the Financial Industry Regulatory Authority (“FINRA”) “Suitability Rule,” but not the best that it could have been done to protect investors. Last month FINRA amended its Suitability Rule to conform with SEC Reg. BI and made it clear that stockbrokers now uniformly have duties related to disclosure, care, conflicts and compliance, which are equivalent to the common law “fiduciary duty” standard when making recommendations to retail customers. See, FINRA Regulatory Notice 20-18. 1

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UBS ETRAC Exchange Traded Note Investors: How Do You Recover Your UBS ETRAC Investment Losses?

If you are reading this article, we are guessing you invested in some of those high-dividend paying UBS ETRAC Exchange Traded Notes (ETNs) your stockbroker recommended to increase your retirement income. We would not be surprised if you were also told the UBS ETRAC investments had a proven track record of great returns. You probably also heard: No need to worry about these investments because they were backed by one of the largest brokerage firms in the world – UBS Financial Services, Inc. (UBS). We’re not shocked because that is just what many other investors have told us about the pitch made to them to invest in UBS ETRACs.

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Steepener Structured Products Losses Attorneys

At The Law Offices of Robert Wayne Pearce, P.A., we specialize in representing investors who have suffered losses due to steepener structured products. With over 40 years of experience, our team of highly skilled attorneys understands the complexities of these sophisticated financial instruments and the legal challenges they present. Steepener structured products, including notes and CDs, are designed to pay varying interest rates based on the steepness or flatness of the yield curve. However, these products can lead to significant investment losses when market conditions change, as seen in the yield curve flattening of 2018 and inversion in 2019. Many investors have experienced rapid declines in value and reduced or eliminated interest payments as a result. Preliminary Reading: We offer comprehensive legal services for investors who have been affected by: What Are Steepner Structured Products? Steepener structured products are complex financial instruments that derive their value from the shape of the yield curve. These products, typically issued as notes or CDs, offer variable interest rates based on the difference between long-term and short-term interest rates. For example, a steepener might pay interest equal to a multiple of the difference between the 30-year and 2-year Treasury rates, minus a spread. Steepeners often have long maturities, sometimes up to 20 years, and are generally illiquid as they don’t trade on public exchanges. They may offer attractive initial “teaser” rates for the first year or two, followed by uncertain future payments. For instance, a steepener might pay 5% for the first year, but subsequent payments could drop significantly or cease entirely if the yield curve flattens. The risks of steepeners became apparent in 2018 when the yield curve flattened, causing many of these products to rapidly decline in value. The situation worsened in 2019 when the yield curve inverted, leading to further losses. During these periods, many investors saw their interest payments reduced dramatically or eliminated altogether. While often marketed as safe, high-quality fixed-income investments, steepeners carry significant risks. These include potential loss of principal, reduced or eliminated interest payments, and difficulty in valuing or selling the product before maturity. The complexity of steepeners makes them challenging for many retail investors to fully understand. For example, some brokers have faced legal action for misrepresenting steepeners as “bonds” or failing to adequately disclose their risks. In one case, a family filed a FINRA arbitration claim seeking over $1 million in damages due to unsuitable recommendations in these products. Given their complexity and potential for misrepresentation, proper disclosure and suitability assessment are crucial when recommending steepeners to retail investors. Financial advisors must ensure clients understand the product’s structure, risks, and potential outcomes under various market conditions. How We Can Help If You’ve Suffered Losses Due to Steepener Structured Notes Our team is well-versed in FINRA arbitration and mediation proceedings, and we pursue claims for fraud, misrepresentation, breach of fiduciary duty, and failure to supervise. We work tirelessly to secure the best possible outcome for our clients, operating on a contingency fee basis to ensure that justice is accessible to all. If you’ve experienced losses due to steepener structured products or other complex derivatives, don’t hesitate to reach out. Contact The Law Offices of Robert Wayne Pearce, P.A. for a free initial consultation and let our experienced securities law attorneys fight for your rights and recover your structured notes investment losses. We are investigating and claims against brokerage firms including Centaurus Financial, Inc., J.P. Turner & Company, LLC, Aegis Capital Corp., Wells Fargo Advisors, and other brokerage firms for structured products investment losses. Please call us if you purchased steepeners through Ricky Mantei (CRD# 1098981), Cindy Chiellini (CRD# 1015592), Katherine Nishnic (CRD# 2499553), Dana Matthew Hawkins (CRD# 5731136), Alan Applebaum (CRD# 500336) or Joseph Andreoli (CRD#1718688). Contact a Steepener Investment Fraud Attorney We have been retained by many investors to file FINRA arbitration claims against brokerage firms to recover their losses. Our firm has been very successful in making recoveries for our clients throughout the United States for investment fraud and has recovered over $175 million for investors. Was it just the market or were you mislead to invest in unsuitable steepener investments? Call Attorney Pearce at 1-800-SEC-ATTY (732-2889) with any questions you may have about how you may recover your steepener investment losses.

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EquiAlt Private Placement Investment Losses

We are investigating and representing investors against FINRA-registered brokerage firms and financial advisors who offered and sold securities issued by affiliates of EquiAlt, LLC (EquiAlt), a private real estate company which organized at least four private placements: EquiAlt Fund, LLC; EquiAlt Fund II,LLC; EquiAlt Fund III, LLC; and EA Sip, LLC (collectively referred to as the EquiAlt Funds). According to a recent SEC Complaint, Brian Davison (Davison) and Barry Rybicki (Rybicki) offered and sold $175 million of unregistered debentures issued by the EquiAlt Funds to over 1,100 investors nationwide. The SEC alleged that Davison, Rybicki, and others committed securities fraud by misrepresenting the debentures as “secure,” “safe,” “low risk,” and “conservative.” Further, while investors were promised “that substantially all of their money would be used to purchase real estate in distressed markets in the United States and their investments would yield generous returns … EquiAlt, Davison, and Rybicki misappropriated millions in investor funds for their own personal use and benefit.” According to the SEC, the revenues that were generated by the EquiAlt Funds became insufficient to pay the interest owed to investors. As a result, the SEC alleged “the Defendants resorted to [a Ponzi Scheme] fraud, using new investor money to pay the returns promised to existing investors.” While many of the sales were solicited by unregistered EquiAlt salespersons, it is reported there were many sales by small offices of registered salespersons associated with large independent FINRA-registered stockbrokerage and insurance firms primarily located in Florida, Arizona, California, and Nevada, and many other states nationwide. It is alleged that EquiAlt salespersons received “commissions of anywhere between 10%-14%,” which is extraordinarily high for the sale of any investment product. Thus, there was such a strong incentive to sell these debentures by any means. It is likely that many of the FINRA registered brokerage firms did not authorize sales of the EquiAlt Fund debentures and that no due diligence or any other investigation of the company or its investment offerings were ever conducted. Consequently, it is very likely that the EquiAlt Funds were sold via misrepresentations and misleading statements. We have learned that investors who purchased the EquiAlt Funds debentures through FINRA-registered brokerage firm representatives also received the same sales pitch; that is, the debentures are “secure,” “safe,” “low risk,” and “conservative” investments, which was untrue which constitutes securities fraud. If you invested in any of the EquiAlt Funds private placements, you may be able to recoup your losses through a FINRA arbitration proceeding. Mr. Pearce has over 40 years of experience with private placement investment disputes and recovering money for investors lost in Ponzi Schemes. The cases we accept will be filed against FINRA registered broker-dealers for misrepresentation, omissions due to failed due diligence, unsuitable investment recommendations, and unauthorized private securities transactions otherwise known as “selling away.” If Attorney Pearce accepts your case there will be no attorney’s fee or arbitration expenses unless we recover funds for you in a settlement with the brokerage or through an arbitration award. Call 1-800-SEC-ATTY (1-800-732-2889) or email us now and get your questions answered and top notch representation in connection with your EquiAlt Funds private placement investments. If you purchased your investment directly from EquiAlt or BR Support Services, your recovery will probably be limited to what assets the Court Appointed Receiver is able to locate, liquidate, and distribute to investors. However, please call us to find out what recourse is available for this investment fraud.

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Investigations and Prosecutions of Early Retirement Scams

Looking for fresh capital to invest in order to earn commissions, the early retirement scam has gained popularity among unethical investment advisors and brokers throughout the United States. The Law offices of Robert Wayne Pearce, P.A. is representing retirees who were tricked into taking lump sum retirement payments in lieu of the traditional pension payments they slaved away for many years with promises of greater growth and more income with little or no risk. We are also representing other baby boomers, near retirement, who were falsely promised security and income at an earlier stage in their life by accepting early retirement packages or just retiring early and cashing out their 401(k) plan. According to Attorney Pearce many investors have fallen prey to these schemes through elaborate seminars and financial projections that misrepresent or do not fully disclose all of the assumptions or the underlying projections and/or risks of the investment program. Representing clients throughout Florida and nationwide. Too many retirees have elected the lump sum option based on the advice of trusted financial professionals. In these cases, the financial professional improperly recommended the lump sum option because that was the only way that his or her firm could gain control of the retirement assets and generate commissions. As a result, the investors sustained substantial losses and retained our law firm to recover their nest egg. For more information on Early Retirement Scams and our cases, click on the links below: Watch Out for Early Retirement Scams Regulation Best Interest (Reg. BI): Better But Not the Best! 72(t) Early Retirement-Not for me! FREE INITIAL CONSULTATION WITH ATTORNEYS WHO UNDERSTAND EARLY RETIREMENT SCAMS The Law offices of Robert Wayne Pearce, P.A. understands and has substantial experience with early retirement scams. We represent victims of such scams and constantly strives to secure justice. Attorney Pearce provides a complete review of your case and fully explains your legal options when you have been scammed out of your retirement funds by unscrupulous brokers and financial advisors. The firm works to ensure that you have all of the information necessary to make a sound decision before any action is taken in your case. For dedicated representation by a law firm with substantial experience in all kinds of securities, commodities and investment disputes, contact the firm by telephone at 561-338-0037 or toll free at 800-732-2889 or via e-mail. We may also be able to arrange a meeting with you at offices located in Boca Raton, Fort Lauderdale, Miami and West Palm Beach, Florida and elsewhere. 72 (t) Early Retirement-Not for Me! Watch Out for Early Retirement Scams

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SEC Halts Alleged EquiAlt Ponzi Scheme: How do Investors Recover Their Losses?

On February 11, 2020, the United States Securities and Exchange Commission (“SEC”) filed a Complaint for injunctive relief to halt an alleged ongoing fraud conducted by EquiAlt LLC (“EquiAlt”), a private real estate investment company that controlled the business operations of EquiAlt and its four real estate investment funds: EquiAlt Fund, LLC (“Fund I”); EquiAlt Fund II, LLC (“Fund II”); EquiAlt Fund III (“Fund III”); and EA SIP, LLC (“EA SIP Fund”) (collectively referred to as the “EquiAlt Funds”). Simultaneously, the SEC and filed an Emergency Motion to freeze all of the Defendant assets and appoint a Receiver to marshall all of the assets and take control of EquiAlt and the EquiAlt Funds. The Court entered an Order that granted the SEC’s request for Temporary Restraining Order and Asset Freeze and another Order Appointing a Receiver.

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72 (t) Early Retirement-Not for Me!

Section 72 (t) of the Internal Revenue Code is often touted as the secret to early retirement by brokers and financial advisors at free seminars and free lunches for employees of major corporations with profit-sharing and pension plans and 401(k)s. Presentations are made at upscale hotels and restaurants to induce the employees to retire or cash out their 401(k)s earlier than they might otherwise have done through a fairly unknown loophole that allows you to avoid the IRS penalty for early withdrawal. Employees are also promised that that they can cash in their retirement savings in their 40- 50s, reinvest the money, and live off the proceeds for the rest of their lives. But there is a lot more to early retirement benefits that just avoiding the IRS penalty.

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