EFTA Document EFTA01386760

Case 1:18-cv-07580 Document 1 Filed 08/20/18 Page 14 of 26 substantial amounts of the proceeds from the sales of the securities to meet TFC's operating expenses; (viii) created phony receivables to misrepresent the true financial ability to repay Bonds; and (ix) agreed from the outset of the SEC's investigation to take whatever steps they deemed necessary to obstruct that investigation and conceal their criminal activities. 60. Beginning in the early 1990's, approximately one hundred (100)