Final October BehindMLM lined YEP begging the general public for $1 million, to cowl $4.2 million in losses in 2020.
On the time I famous Pushed Buying and selling, which was curiously absent from YEP’s SEC filings.
I additionally famous a “coming quickly” automation element being pitched to founders:
That’s now launched, seeing YEP including securities fraud to its MLM providing.
Effectively, at the least up till very just lately.
Pushed Buying and selling presents automated buying and selling to Superior and Mastery tier associates.
- Superior prices $1000 after which $150 a month
- Mastery prices $2000 after which $200 a month
Superior permits a Pushed Buying and selling affiliate to automate foreign exchange or crypto buying and selling. Mastery permits an affiliate to run two bots concurrently.
As marketed by YEP themselves, the Pushed Buying and selling “automation instrument”
Take(s) the Energy of DRIVEN’s Copy/Paste Buying and selling and Supercharge(s) it With an AI AUTOMATION Assistant That Helps You Handle Trades and Handle Danger Successfully.
It’s this automation that constitutes a securities providing.
To ascertain a securities providing we first have to determine an funding contract. As per the Howey Take a look at;
An funding contract exists if there’s an “funding of cash in a standard enterprise with an inexpensive expectation of income to be derived from the efforts of others.”
With respect to Pushed Buying and selling’s automation providing;
- Pushed Buying and selling associates make investments funds by means of Pushed Buying and selling’s automation providing (the “frequent enterprise”)
- Pushed Buying and selling associates do that on a “affordable expectation of income”
- mentioned income are derived by means of Pushed Buying and selling’s automation providing, constituting “the efforts of others”.
Since noting YEP’s SEC submitting final October, the corporate has filed 5 amendments to its digital shares providing.
- on November sixteenth YEP filed to increase the supply to December sixteenth, 2021
- on November thirtieth YEP “up to date their pitch deck and made a number of modifications to the providing web page”
- on December 14th YEP filed to increase the supply to February 18th, 2022
- on February 18th YEP filed to increase the supply to March fifteenth, 2022
- on February twenty fourth YEP “eliminated their cmo and separated from product line “pushed” which was a major income for the corporate
What?
If YEP’s February twenty fourth submitting is to be believed, the corporate has dumped Pushed Buying and selling and within the course of doubtless obliterated itself financially. Pending quarterly and annual filings although, that’s a narrative for an additional day.
With YEP and CEO Jimmy Ezzell out of the image, who’s working Pushed Buying and selling?
A go to to Pushed Buying and selling’s web site reveals the corporate is headed up by CEO Cory Kromray.
Livia Fisher-Kane, Pushed Buying and selling’s CMO, is the referenced terminated CMO in YEP’s February twenty fourth SEC submitting.
In line with his LinkedIn profile, Cory Kromray is predicated out of Florida. Value noting is Pushed Buying and selling LLC, included in Florida by Kromray, cites him with a road deal with in Wisconsin.
He was working a “advertising and marketing consulting company/social media administration” firm, earlier than reinventing himself as a buying and selling bro in December 2021.
Oh and Kromray can also be positively a crypto bro, having already rolled an NFT cashgrab into Pushed Buying and selling:
Having established YEP is not within the image, our consideration now turns as to if Pushed Buying and selling have registered themselves with the SEC.
They’ll additionally have to register with the CFTC, as automated foreign currency trading triggers Commodity Buying and selling Advisor registration beneath the Commodity Trade Act.
Neither Pushed Buying and selling or Cory Kromray are registered with the SEC or CFTC. This implies the corporate is working illegally within the US.
At time of publication Alexa ranks the US as the highest supply of site visitors to Pushed Buying and selling’s web site (43%).
The UK (35%) and Australia (23%) are respectively the second and third largest sources of site visitors. Pushed Buying and selling isn’t registered to supply securities in these jurisdictions both.
Replace fifth April 2022 – Within the Pushed Buying and selling LLC incorporation in Florida, Kromray has offered what seems to be a Wisconsin deal with however the offered state is “FL”.
I’ve obtained unbiased affirmation Kromray is predicated out of Wisconsin so the Florida submitting seems to be an error.