Apex first appeared on BehindMLM’s radar a couple of months in the past, as a part of our ongoing Kuvera securities fraud protection.
(Apex) will educate you make a passive revenue.
You make a one off funding and receives a commission each single month for the following 5 years.
That was again in Could and since then, Apex has launched as a stand-alone alternative.
As we speak we check out the place Apex suits into Investview’s funding alternative steady.
Apex’s Merchandise
Apex has no retailable services or products, with associates solely capable of market Apex affiliate membership itself.
Apex’s Compensation Plan
Apex associates spend money on models, on the promise of an marketed month-to-month $500 ROI.
Apex pays $500 a month per unit invested in for 5 years. This equates to a complete return of $30,000.
Apex models price $11,000 and not using a principal assure and $13,750 with.
Apex advertising and marketing represents the principal assure pays out $11,000 if something goes flawed through the five-year funding contract interval.
Apex Affiliate Ranks
There are ten affiliate ranks inside Apex’s compensation plan.
Together with their respective qualification standards, they’re as follows:
- Affiliate – enroll as an Apex affiliate
- L1 – promote a minimum of one Apex funding unit
- L2 – recruit and keep two investing associates
- L3 – personally recruit three associates and generate a downline of a minimum of twenty investing associates or generate fifty downline Apex unit investments
- L4 – personally recruit 4 associates and generate a downline of a minimum of fifty investing associates or generate 100 and twenty-five downline Apex unit investments
- L5 – personally recruit 5 associates and generate a downline of a minimum of 100 and fifty investing associates or generate 300 and seventy-five downline Apex unit investments
- L6 – personally recruit six associates and generate a downline of a minimum of 2 hundred and fifty investing associates or generate 600 and twenty-five downline Apex unit investments
- L7 – personally recruit seven associates and generate a downline of a minimum of 5 hundred investing associates or generate one thousand 2 hundred and fifty downline Apex unit investments
- L8 – personally recruit eight associates and generate a downline of a minimum of one thousand investing associates or generate two thousand 5 hundred downline Apex unit investments
- L9 – personally recruit 9 associates and generate a downline of a minimum of two thousand investing associates or generate 5 thousand downline Apex unit investments
Notice that throughout ranks L3 to L6, not more than 40% of required qualification standards can come from anybody unilevel crew leg.
For ranks L7 to L9, this qualification cap is decreased to 30%.
Recruitment Commissions
Apex pays commissions on unit funding down two ranges of recruitment:
- $500 on stage 1 (personally recruited associates); and
- $100 on stage 2 (associates recruited by your stage 1 associates)
Residual Commissions (matrix)
Apex pays residual commissions by way of a 3×2 matrix.
A 3×2 matrix locations an affiliate on the prime of a matrix, with three positions instantly underneath them:
These three positions kind the primary stage of the matrix. The second stage of the matrix is generated by splitting every of those first three positions into one other three positions every (9 positions).
In whole, a 3×2 matrix has twelve positions to fill.
Positions within the matrix are stuffed by way of direct and oblique recruitment of Apex associates.
For every unit invested by associates positioned into the matrix, a $40 a month residual fee is paid out.
Residual Commissions (unilevel)
Residual unilevel commissions seem to increase residual commissions past an Apex affiliate’s 3×2 matrix.
A unilevel compensation construction locations an affiliate on the prime of a unilevel crew, with each personally recruited affiliate positioned instantly underneath them (stage 1):
If any stage 1 associates recruit new associates, they’re positioned on stage 2 of the unique affiliate’s unilevel crew.
If any stage 2 associates recruit new associates, they’re positioned on stage 3 and so forth and so forth down a theoretical infinite variety of ranges.
Apex caps residual commissions at 9 unilevel crew ranges.
Though not explicitly clarified, I consider Apex associates must unlock unilevel ranges by qualifying by means of ranks L1 to L9 (consult with rank qualification standards above).
$30 is paid out per thirty days per unit invested by an affiliate throughout these 9 ranges.
Residual unilevel commissions expire on the finish of the 5 yr unit funding contract they’re paid out on.
Examine Match Bonus
Apex seems to pay the Examine Match Bonus on residual commissions earned, down 4 generations.
Apex defines a era when an affiliate is present in a unilevel crew leg who has stuffed their 3×2 matrix.
If such an affiliate exists in a unilevel crew leg, they cap off the primary era for that leg. The second generations begins instantly beneath them.
If a second affiliate who has stuffed their 3×2 matrix is discovered deeper within the leg, the second era is capped off and the third begins.
If no such affiliate exists, the second era extends down the complete depth of the leg.
Utilizing this generational construction, Apex associates can earn a ten% Examine Bonus Match on as much as 4 generations per unilevel crew leg.
- to unlock one era match an Apex affiliate should have stuffed their 3×2 matrix
- to unlock two generations match an Apex affiliate should have one personally recruited affiliate who has additionally stuffed their 3×2 matrix
- to unlock three generations match an Apex affiliate should have two personally recruited associates who’ve stuffed their 3×3 matrices
- to unlock 4 generations match an Apex affiliate should have three personally recruited associates who’ve stuffed their 3×3 matrices
Quarterly Bonus Pool
Apex takes an undisclosed proportion of company-wide invested funds and locations it into the Quarterly Bonus Pool.
To qualify for a share within the Quarterly Bonus Pool Apex associates should fill their first 3×2 matrix.
An extra Quarterly Bonus Pool share is awarded on the primary affiliate who fills their first 3×2 matrix in every unilevel leg.
When an Apex affiliate recruits an affiliate they create a brand new unilevel crew leg.
Associates recruited by that affiliate, associates these associates recruit and so forth are positioned in that leg.
There isn’t a restrict to the variety of unilevel crew legs an Apex affiliate can create.
Quarterly Bonus Pool shares pay as much as $15,000 per share per quarter for 5 years.
Notice that Quarterly Bonus Pool shares don’t pay out till 12 months after they’re earned (4 quarters).
Becoming a member of Apex
Apex affiliate membership is free.
Full participation within the connected revenue alternative requires a minimal $11,000 (no principal insurance coverage) or $13,750 (with principal insurance coverage) funding.
Apex additionally provides a “4 and free” bonus pack, wherein associates spend money on 4 models and obtain a fifth without cost.
Funding, returns and commissions inside Apex are paid in both USD or bitcoin.
Conclusion
Apex associates make investments $11,000 or $13,750 a pop on the promise of a five-year $500 a month ROI.
Supposedly Apex affiliate buyers are shopping for “proprietary modular expertise” {hardware} from SafeTek, who then leases again the machines from the affiliate for 60 months.
SafeTek purportedly generate exterior ROI income by utilizing the {hardware} on
Synthetic Intelligence, Blockchain Expertise, Digital Actuality, 3D Rendering, Cryptographic and Information Mining, Monetary Expertise, Well being Expertise, and extra.
SafeTek is owned by Investview and, as disclosed in SEC filings, up till just lately was WealthGen International, LLC.
SAFETek, LLC (previously WealthGen International, LLC) is a brand new addition that we’re at present establishing for enlargement plans within the high-speed processing computing house.
WealthGen International was a part of Investview’s failed cryptocurrency mining operations.
That is vital, as a result of in keeping with a JVA between Investview and various different firms (extra on the JVA later), all Apex associates are doing is shopping for bitcoin mining {hardware}.
The {hardware} itself is bought from Bitex Gross sales LLC and hosted with FiberTek Internet hosting LLC.
James Wolfgramm is the CEO of each firms.
As per the JVA, the {hardware} is known as “playing cards”.
{Hardware} is outlined as a Information Processing Card which could have a Wholesale worth prolonged to the Shopper of $6,500.00 U.S.D. beginning upon the first order positioned by the Shopper and persevering with for 1 yr.
Every card is able to a most output which might differ between the equal of 750 okay/sols to 1200 okay/sols, relying on manufacturing management.
Traditionally, Fibertek overclocking knowledge processing playing cards can improve throughput as much as 750 Ksols with out liquid cooling, as much as 1200 ksols with liquid cooling, or equal hashrate per card, and on common 200 ksols or equal hashrate for non-overclocked playing cards.
If an equal hashrate isn’t attainable, the host will at all times overclock to most capability.
The mining earnings earned by the mining companies rendered by the Host on the Shopper’s Tools shall be paid to the Shopper on a month-to-month foundation up till April 1st, 2019 and thereafter every day.
Regardless of the AI, blockchain tech, digital actuality and so forth. and so forth. spiel, all Apex are doing is mining bitcoin by means of a third-party.
In different phrases, Safetek is doing precisely what WealthGen International, LLC was supposedly doing. All that’s modified is the title.
Again to Apex’s funding alternative…
With respect to the MLM business, securities choices are recognized as per the Howey Check.
This includes establishing whether or not or not an funding contract is current
As outlined by the Howey Check, an funding
an “funding contract” for the needs of the Securities Act (is) a contract, transaction or scheme whereby an individual invests his cash in a standard enterprise and is led to count on earnings solely from the efforts of the promoter or a 3rd social gathering.
In Apex, associates make investments funds in a standard enterprise (Apex itself), as a result of they’re “led to count on earnings solely from the efforts of” Apex itself (by way of bitcoin mining).
Apex associates do nothing in the direction of producing returns aside from handing over 1000’s of {dollars}.
Regardless of clearly being a securities providing, Investview is adamant it isn’t as a result of… properly, for causes which have nothing to do with the Howey Check or securities regulation.
Threat of loss and “but it surely’s a lease!” pseudo-compliance don’t have anything to do with MLM alternative securities regulation.
If you happen to’re dumping cash into an MLM firm on the illustration you’ll make passive returns, that’s a safety. Interval.
So naturally Investview hasn’t reported their Apex securities providing to the SEC.
There’s sufficient third-parties concerned to recommend Apex isn’t a blatant Ponzi scheme. However the reality stays they’re hedging viability on producing greater than $500 a month by way of bitcoin mining.
If Apex and all the businesses connected to it don’t cowl their prices and generate $500 to pay out on every unit, what then?
There’s additionally the $2750 safety plan, which in itself can also be a passive securities providing:
All of this seems like one thing the SEC needs to be wanting into. Then once more, we’ve been reporting Investview’s dodgy securities choices since 2015.
The CFTC investigated and fined Investview a $150,000 final yr, however since then nothing. That’s regardless of Investview occurring to launch a number of questionable unregistered securities choices.
One very last thing I need to contact on is the supply of among the screenshots above. We bought them from an Apex presentation Jeremy Roma did on or round June 1st, 2019.
Final we heard of Roma was in late 2018. On the time he was following Holton Buggs into the failed IQ Chain Ponzi scheme.
A three way partnership settlement filed by Investview again in March reveals Roma is closely concerned in Apex.
Roma, together with Investview executives Ryan Smith and Annette Raynor, and AI Information Consulting, seemingly a shell firm included within the UAE and owned by Carlos Benvenuti, are listed as Managing Members of Safetek.
Roma additionally owns Freedom Enterprise LLC, one of many firms pertaining to Investview’s filed three way partnership settlement.
Each Benvenuti and Roma are former Organo Gold distributors, which seems to be their private connection.
The bitcoin mining {hardware} Apex associates are investing in are bought from Bitex Gross sales LLC.
Carlos Benvenuti and Jeremy Roma, by means of their respective firms, have a grasp buy settlement with Bitex.
Probably additionally in violation of securities regulation, none of that is disclosed by Roma in his Apex presentation.
Replace seventeenth October 2019 – Readers within the feedback beneath revealed that the JVA cited on this overview has since been terminated. This prompted me to take a more in-depth take a look at Investview’s latest SEC filings.
Investview certainly terminated its JVA with AI Information Consultancy LLC (Carlos Benvenuti) and Freedom Enterprise (Jeremy Roma) on September fifteenth.
Surviving the JVA termination is a income share settlement between Investview and Freedom Enterprise.
The income share settlement reveals Jeremy Roma has arrange Freedom Enterprise as a UAE shell firm.
The tackle used is similar as AI Information Consultancy, suggesting Roma and Benvenuti arrange their respective shell firms across the similar time.
The income share settlement notes the creation of Apex Tek, which is one other renamed Investview firm (previously Razor Information LLC).
APEX TEK will market and promote the product often called APEX and SAFETEK will lease again and deploy the gear in a wide range of knowledge processing environments and functions.
The Events have labored intently to ascertain this system, firms and construction. Each entities are in operation and the APEX product was formally launched by means of the joint efforts of the events on August thirty first, 2019.
The settlement positions Jeremy Roma as Vice Presdient of Apex Tek and President of Safetek.
Whereas the earlier JVA disclosed the character and supply of bitcoin mining rigs used to fund returns, Roma’s income sharing settlement isn’t particular.
APEX TEK will supply, buy and re-sell the elements required for the APEX program.
The place Apex Tek is getting their {hardware} from is unclear and never disclosed to both the SEC or Apex affiliate buyers.
What we do know is Roma is scooping up former OneCoin scammers to entrance Apex.
Mariana Lopez and Jose Gordo up till just lately had been distinguished OneCoin promoters.
The pair targeted on concentrating on South American buyers, and collectively probably made off with a large chunk of OneCoin sufferer’s cash.
The DOJ allege OneCoin is a $4 billion greenback Ponzi scheme. Felony proceedings have subsequently been initiated towards a number of OneCoin executives.
None of this appears to hassle Jeremy Roma, Apex or Investview although.
One remaining fascinating tidbit I got here throughout in Investview’s filings is their precarious monetary place.
Since inception by means of to March thirty first, 2019, Investview has incurred operational losses of $25,096,983.
All through 2019 the corporate has gone on to lose a number of extra hundreds of thousands.
Isn’t it unusual that an organization who continues to launch questionable funding alternatives itself can’t flip a revenue?