In the Matter of Curtis A. Peterson
Admin. Proc. File No. 3-17391

On August 23, 2016, the Commission instituted and partially settled proceedings against Curtis A. Peterson (“Respondent”) arising from his participation as an unregistered broker-dealer in the offer and sale of securities by interstate commerce (the “Order”). In the Order, the Commission found that the Respondent acted as an unregistered sales agent of JCS Enterprises, Inc. (“JCS”) and T.B.T.I., Inc. (“TBTI”) by having offered and sold JCS’s and TBTI’s investment contracts in JCS’s Virtual Concierge program, and the Respondent earned transaction-based compensation from each sale. From approximately March 2013 through December 2013, the Respondent, individually and/or through a company under his control received $584,550.00 in transaction-based compensation from JCS and TBTI in exchange for soliciting and securing investors through the use of telephone and/or email. The Commission found that the Respondent willfully violated Section 15(a)(1) of the Securities Exchange Act of 1934. The Commission ordered that the Respondent pay a civil money penalty of $7,500.00. Pursuant to the Order, the Respondent agreed to additional proceedings to determine whether it is appropriate to order disgorgement of ill-gotten gains, and, if so, the amount of the disgorgement. If disgorgement is ordered, prejudgment interest will be calculated thereon from March 19, 2013 through April 7, 2014. The Commission also created a Fair Fund pursuant to Section 308(a) of the Sarbanes-Oxley Act of 2002, as amended, for all funds received pursuant to the Order, including any disgorgement and prejudgment interest amounts that may be ordered as the result of the additional proceedings agreed upon in the Order.

The Commission further ordered that all funds paid by the Respondent pursuant to the Order be transferred to the Receiver, James D. Sallah, appointed in the related Commission action, SEC v. JCS Enterprises, Inc., et al., Case No. 14-80468-CV-DMM (S.D. Fla.) for distribution to injured investors in accordance with a distribution plan to be approved by the court in that litigation. See the Commission’s order: Release No. 34-78639.