SEC Charges Southern California Resident with Unregistered Broker Activity

ADMINISTRATIVE PROCEEDING
File No. 3-22113

September 16, 2024 - The Securities and Exchange Commission today announced settled charges against Ralph M. Trigg for unregistered broker activity.

According to the SEC’s order, from at least November 2016 through May 2018, Trigg acted as an unregistered broker by soliciting investors for and selling investments in two pooled investment vehicles created by Black Hawk Funding, Inc. The order finds that Trigg regularly solicited investors through in-person meetings as well as by phone and email communications. Among other things, the order finds that Trigg provided investors with offering and marketing materials; took investors on tours of a cannabis campus located in Coachella, California where Black Hawk Funding invested a significant portion of the money raised from investors and as part of the tours provided presentations on the benefits of the pooled investment vehicles; and took steps to ensure that investors executed the participation agreements and transferred the money needed to complete their investments. Additionally, according to the SEC, Trigg acted as an unregistered broker by soliciting investors to purchase securities of a separate Black Hawk-affiliated cannabis-industry entity as well. According to the order, Trigg received transaction-based compensation for each purchase of securities by the investors he solicited that totaled at least $211,000.

The SEC order finds that Trigg willfully violated Section 15(a) of the Securities Exchange Act of 1934. Without admitting or denying the SEC’s findings, Trigg agreed to: (1) a cease-and-desist order; (2) associational and penny stock bars as well as an investment company prohibition against him with the right to apply for reentry after two years; (3) disgorgement of $211,000, with prejudgment interest of $66,424; and (4) a civil penalty of $75,000. 

The SEC’s investigation was conducted by Kashya Shei and John Roscigno, with the assistance of trial counsel Sheila O’Callaghan, and supervised by Jeremy Pendrey and Jason H. Lee, all of the San Francisco Regional Office.