In the Matter of James Goodland, et al.
Admin. Proc. File No. 3-16878

On September 30, 2015, the Commission instituted and simultaneously settled administrative and cease-and-desist proceedings (the “Order”) against Howard Richards (“Richards”). In the Order, the Commission found that, from January 2010 through July 2013, Richards, an investment advisory representative, associated with Securus Wealth Management, LLC, engaged in a manipulative scheme to support the market price of the common stock of Gatekeeper USA, Inc. (“Gatekeeper”), which he thought would help Gatekeeper to obtain financing. The Commission also found that the Richards failed to disclose to his clients, his significant conflict of interest arising from his ownership of Gatekeeper shares in breach of his fiduciary duty as an investment adviser. The Commission ordered Richards to pay disgorgement, prejudgment interest, and civil money penalties totaling $144,000.00 in installments over the period of one year. The Commission also created a Fair Fund, pursuant to Section 308(a) of the Sarbanes-Oxley Act of 2002, as amended, so the penalty, along with the disgorgement and prejudgment interest, collected can be distributed to those harmed by Richards’ misconduct. See the Commission’s order:  Release No. 34-76058. 

In a related action, also on September 30, 2015, the Commission instituted and simultaneously settled administrative and cease-and-desist proceedings (the “Company Order”) against James Goodland (“Goodland”) and Securus Wealth Management, LLC (“Securus”). In the Company Order, the Commission found that, from January 2010 through July 2013, Securus, an investment adviser registered with the Commission, and Goodland, its President and Chief Compliance Officer, failed to reasonably supervise Richards whom Goodland directly supervised. Securus and Goodland also failed to adopt and implement an adequate system on internal controls that would have prevented and detected violations of the Advisers Act. The Commission ordered Goodland to pay a $30,000.00 civil money penalty. The Commission also created a Fair Fund, pursuant to the Sarbanes-Oxley Act of 2002, as amended, for the penalty collected from Goodland. The Company Order also provided that the funds could be distributed by the Fair Fund established in In the Matter of Howard Richards, Admin. Proc. File No. 3-16877. See the Commission’s order:  Release No. IA-4213. 

Richards and Goodland have paid, as ordered, a total of $174,000.00 into their respective Fair Funds, which will be consolidated into one Fair Fund for the distribution to harmed investors.

On March 8, 2018, the Commission issued an order appointing Miller Kaplan Arase LLP as the Tax Administrator of the Fair Fund.

On March 16, 2018, the Commission issued an order appointing Analytics Consulting Services, LLC as the Fund Administrator to oversee the administration and distribution of the Fair Fund, and waived the administrator’s bond. See the Commission’s Order: Release No. 34-82902. 

On November 23, 2021, the Commission published a notice of the proposed plan of distribution and opportunity for comment and simultaneously published the proposed plan of distribution (“Proposed Plan”). The notice provides the public with 30 days to submit their comments on the Proposed Plan. See the Commission’s Notice:  Release No. 34-93664 and the Proposed Plan. 

On January 13, 2022, the Commission issued an order approving the Proposed Plan and simultaneously posted the approved plan of distribution (the “Plan”). See the Commission’s Order: Release No. 34-93980 and the Plan.

For more information, please contact the Fund Administrator:

Analytics Consulting, LLC
Telephone Number: 877-318-1027
Website: www.analyticsllc.com
Email: info@analyticsllc.com