2. On October 11, 2013, a final judgment was entered by consent against Baggs, permanently enjoining him from future violations of Sections 5(a), 5(c), and 17(a) of the Securities Act of 1933 ("Securities Act"), Sections 10(b) and 15(a) of the Exchange Act and Rule 10b-5 adopted thereunder, in the civil action entitled Securities and Exchange Commission v. Bernard H. Butts Jr., et al., Civil Action Number 1:13-CV- 23115, in the United States District Court for the Southern District of Florida. On October 25, 2016, the district court entered a final judgment against Baggs ordering him to pay disgorgement of $4,970.00 representing profits gained as a result of the conduct alleged in the complaint, together with prejudgment interest in the amount of $498.28, and a civil penalty in the amount of $150,000.00 pursuant to Section 20(d)(2)(C) of the Securities Act and Section 21(d)(3)(B) of the Exchange Act.

3. The Commission's complaint alleged that Baggs acted as a sales agent that offered and sold securities in a fictitious prime bank instrument trading program offered by Worldwide Funding. Baggs brought investors into the scheme with the promise of extraordinary profits. As part of the scheme Baggs told investors that an investment of between $60,000 and $90,000 with Worldwide Funding would generate profits of approximately 14% per week for 40 to 42 weeks. The complaint alleged that defendants falsely promised that when an investor's funds were deposited into an attorney's trust account, the attorney would not release the funds until he received proof from the receiving bank that a €10,000,000 Standby Letter of Credit ("SBLC") had been deposited into a securities trading program that was to generate the profits for investors. The complaint alleged that Baggs and others did not disclose that instead of using the investors' funds to obtain SBLCs they misappropriated investors' funds and paid the sales agents approximately 10% of the investor's funds. Contrary to the representations, the acquisition of the SBLCs never occurred, no loans were obtained, and no promised returns were earned in a trading program or paid to investors. Over more than a year, Baggs and others obtained at least $3.5 million from approximately forty-five investors nationwide and in foreign countries by making false and misleading statements or omitting material facts in the offer and sale of securities, which were not registered with the Commission at the time they were sold. In addition, the complaint alleged that Baggs was not registered as a broker or dealer when he offered the securities of Worldwide Funding.

• association with any broker, dealer, investment adviser, municipal securities dealer, municipal advisor, transfer agent, or nationally recognized statistical rating organization;  
• participating in any offering of a penny stock; and
• acting as a promoter, finder, consultant, agent or other person who engages in activities with a broker, dealer or issuer for purposes of the issuance or trading in any penny stock, or inducing or attempting to induce the purchase or sale of any penny stock.