• As VPA’s president, Poinsetta offered and sold unregistered securities primarily to Michigan investors.
• Poinsetta made false statements to OFIS regarding VPA’s application for registration as an investment adviser.
• Poinsetta organized and operated a “Ponzi” scheme where she falsely claimed that she was a Certified Financial Planner and convinced many investors that she could help them generate greater returns on their investments. Promising a high rate of return, she would allegedly deposit the funds into a commercial checking account that she controlled. She placed well over $1 million of investor funds in this non-interest bearing checking account. She told investors that they could withdraw funds at any time, but in many cases investors were unable to actually receive their funds when it was requested or they received checks that bounced.
• Poinsetta offered and sold unregistered securities from 1997 to 2003 in both Real Land Securities, Inc., and Capital Venture Fund I Limited Partnership (also known as the Capital Venture Fund).
• VPA was financially insolvent for its last 3 fiscal years of operation (2001, through and 2003). Despite this, Poinsetta, on behalf of VPA, filed a false financial statement in 2002 with OFIS indicating VPA was solvent.
• Poinsetta continued to operate as a securities agent even after her agent registration was terminated on November 27, 2002.
• In response to investor complaints in 2004, OFIS conducted an examination of VPA. As President and the investment adviser representative for VPA, Poinsetta attempted to interfere with OFIS’ examination by not providing all requested or subpoenaed documents and not allowing OFIS staff to examine all of her firm’s records, in all of which is a violation of the Act.

* * *