Apr. 15, 2020
The proposed plan seems to argue that the harmed De Vere investors should be due the amount that was used to pay the 7% bonuses and not disclosed to investors. This argument seems flawed as the financial harm caused was not my payment of these funds, but the impact of the bonuses had on the resulting unlawful behavior of DeVere IARs that caused me to do take a number of actions that inflicted considerable financial harm, including to partner with De Vere on QROPs resulting in lost gains due to uninvested instructions, engagement in a inappropriate binding contract with RL 360, unexpected tax payments and other activities as outlined in Administrative Proceeding File No.3-18527 These financial impacts are not mathematically linked to the 7% bonuses at all and in fact, are very significantly greater. I would like disclosure on two other matters; - details on the SEC actions, decisions and dates in the 21 months between the creation of the De Vere Fair Fund in 6/4/18 and the announcement of the proposed plan in 3/23/20 whilst those impacted by these actions waited? - details on what credits or debits were made to the $8m De Vere Fair Fund during this period? Peter Hare