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ARTICLE · 11 SEPTEMBER 2012

Financial Fraud Alert - August 2012

This complaint arises from an alleged Ponzi scheme involving the fraudulent sale of promissory notes, marketed as investments in defendants’ premium financing business.

United StatesCriminal Law

Who: Plaintiff: Securities and Exchange Commission

Defendants: Bridge Premium Finance, LLC (f/k/a Berjac of Colorado, LLC); Michael Turnock; and William P. Sullivan, II

What: This complaint arises from an alleged Ponzi scheme involving the fraudulent sale of promissory notes, marketed as investments in defendants' premium financing business. According to the complaint, "[d]efendants raised money from promissory note investors purportedly to provide capital for BPF [Bridge Premium Finance]'s insurance premium financing business – that is, making short-term loans to businesses to enable them to pay their annual commercial insurance premiums." The complaint further alleges that "[d]efendants portrayed the promissory note investments as safe, conservative investments comparable to money market accounts and certificates of deposit, but offering higher rates of interest, up to 12 percent annually." According to the complaint, however, BPF was actually "operated as a

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