You\'re trying to get a free legal opinion that should require establishing a lawyer - client relationship, and a review of the documents, facts and issues. Anything less is just asking for problems, for the attorney offering such opinion without proper foundation, and for the client thinking he can rely upon it. I suggest you consult with experienced qualified counsel to obtain an informed opinion worth relying on. That way when and if legal problems with regulatory agencies or lawsuits arise, you can waive the attorney opinion in the air and claim reasonable reliance.

Are you still looking for help with this matter? It may be a reg D issue or, there may be other issues here. I would need to know all the facts, dates, etc..

Best,

Daniel Bakondi, Esq.

The Law Office of Daniel Bakondi, APLC

870 Market Street, SUite 1161

San Francisco CA 94102

danielbakondi@yahoo.com

415-450-0424

http://www.danielbakondi.com

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