Crowd Funding Portals – Buyer Beware



Eureeca Cease and Desist Order – Why the SEC’s Approach Is Good For CrowdFunding Industry

Last week Eureeca Capital SPC officially became one the first crowdfunding sites to be cited by the Securities and Exchange Commission (“SEC”) for, among other things, failing to take proper measures to verify that purchasers were “accredited” as required by Regulation D Rule 506(c). In response to the SEC’s proceedings against the Dubai based crowdfunding platform, Eureeca submitted an offer of settlement which was accepted by the SEC on November 10, 2014 in the form of a cease and desist order and a $25,000 fine. While we are certain to see more SEC actions as crowdfunding continues to grow in popularity, I see this order as a good sign for the crowdfunding industry in general.


Eureeca is an investment based crowdfunding platform which offers foreign-based equity investments to interested investors. As with any crowdfunding site, Eureeca provides information about various issuers and their available offerings. The problem here, is that this information was accessible to U.S. residents even though the securities were not registered with the SEC. Offering unregistered securities for sale to U.S. residents is a violation Section 5 of the Securities Act of 1933 unless the issuer complies with the requirements for exemption from registration (in this case the requirements of Rule 506(c)). Specifically the allegations made by the SEC against Eureeca were:


These proceedings arise out of Eureeca’s failure to implement procedures reasonably designed to prevent U.S. persons from accessing and investing in securities through its crowdfunding website. Eureeca offered and sold securities in unregistered transactions to U.S. persons and acted as an unregistered broker dealer to U.S. persons. Eureeca violated Sections 5(a) and 5(c) of the Securities Act as a result of the unregistered offer and sale of securities to three U.S. investors because, after generally soliciting, it did not take reasonable steps to verify that the purchasers of the securities were accredited investors, as required under Rule 506(c) of Regulation D under the Securities Act. Eureeca also violatedSEC Section 5(c) of the Securities Act by offering the sale of securities in unregistered transactions between May and September 2013 because it was generally soliciting investors prior to Rule 506(c) being adopted. Additionally, Eureeca violated Section 15(a) of the Exchange Act by acting as an unregistered broker-dealer to U.S. registered users on its website. Eureeca solicited investors and participated in key parts of the transactions.


It should be pointed out that Eureeca’s terms of service specifically state that the offerings are not being made, and cannot be accepted by, United States residents


Eligibility. To be eligible to use the Services, you must be at least 18 years old. At this time, our Services cannot be used by US persons (which are defined as citizens or residents of the U.S., any corporation, partnership or other entity created or organized in or under the laws of the U.S. or any person falling within the definition of the term “U.S. Person” under Regulation S adopted by the Securities and Exchange Commission of the U.S. on 24th April 1990, as amended from time to time). Each investment product and service referred to on the Website is intended to be made available only to non – US persons, and is only available in jurisdictions where that investment product or service may lawfully be made available. You agree that you have all requisite authority to enter into and use the Services contemplated by these Terms of Use. The Website will not be considered a solicitation for or offering of any security, investment product or service to any person in any jurisdiction where such solicitation or offering would be illegal.


Despite the clear disclaimer, the SEC alleges that Eureeca actually allowed over fifty self-identified U.S. residents to register with the site and allowed three of those individuals to actually participate in offerings (by collecting a total of $20,000 from these individuals).Secure or blocked Internet access conceptThe takeaway here for non-United States based equity/debt crowdfunding sites is that waivers and terms of service are not going to be enough in the eyes of the SEC in terms of limiting access to information. Crowdfunding sites will have to take affirmative measures to prevent unqualified person (in this case U.S Residents) from accessing information and participating in offerings.


So why do I say that this order is good for the crowdfunding industry? It’s because of how the SEC chose to handle the situation. The SEC could have chosen to rain hellfire down on Eureeca and imposed any of a number of harsh civil/criminal penalties as an example to the crowdfunding industry but it did not. Instead the SEC gave Eureeca a $25,000 penalty “slap on the wrist.” While the next crowdfunding company might not be so lucky, I was happy to see the SEC taking a very even-handed approach in this matter and not overreacting. As we will inevitably see more actions, I hope that the SEC continues to maintained such an approach.

The Portal on line Crowd Funding area is new since May 12th 2016. The SEC is educating and giving the “benefit of the doubt” in the NEW LAW area – while seriously enforcing the new regulations. We feel they are doing a GREAT JOB and appreciate Mary Jo’s hand as a prosecution expert to assure the public is maximally protected.

CEO SPACE provides legal compliance education on the new law supported by various legal experts on THAT NEW CURRICULUM and to our knowledge offers the only three day training to CEO’s on OVER COMPLIANCE in the new law area. Our next education program is hosted Friday July 22nd at the Westin Lake Las Vegas and guests may enroll for the entire CEO SPACE business growth conference, or just the capital section depending upon the and resource desires.

Berny Dohrmann Chairman of CEO SPACE




My best seller REDEMPTION THE COOPERATION REVOLUTION seems prophetic today. Each phase since 2008 was predicted precisely. The digital world war – and the trade war – we find ourselves in – is predicted in REDEMPTION. We are following historic pattern to world depression and world war exactly – on deviation on time line or old tactics.

Today we find in May 2016 what pundits have known for some time. The USA is reporting its first wage productivity CRISES with dipping productivity for the first time in 30 years – three decades folks.

Now the USA is in down bubbler on worker productivity. How much MORE can the American worker take – already the most productive workers alive in the world today?

Productivity DEFLATION means that higher earnings for wage earner can no longer be sustained. In fact as PRODUCTIVITY DIPS so must wages creating the end game for DEFLATION of VALUE across the globe.

America is now in a full blown PRODUCTIVITY CRISES and there no end in sight. Rather than invest trillions into plant efficiency upgrades and technology to improver worker productivity – 2.7 trillion since 2010 alone is being “diverted” into speculation in COMPANY STOCK BUY BACKS rigging markets and adding no value to the economy. Such enormous speculations rigging the markets are immoral unethical and should be illegal. They once were. Lets go back to the future on regulations.

To force investment CONGRESS must return to TAX CREDIT POLICY to stimulate the economic investment needed to work out of DEFLATION he death spiral to our economy. Without a tax credit plan and soon the lack of investment is going to spiral deflation into bone marrow. The result very well can be depression and world war.

Failed policy is the cause.

In hind sight it is always so obvious.

We’ll keep a light on for you.
Berny Dohrmann- Chairman



PS: Meanwhile the “FOOLS RALLIES” I’ve been writing about are in full swing – why not be a sucker and get roped in this time…this time it will be different right? Ah…not so much really – not so much……..




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Berny Dohrmann – Chairman CEO SPACE


PS: Members do NOT stay home for this ONE …..




The outline of the repeat of financial history has been well laid out in my best selling book REDEMPTION THE COOPERATION REVOLUTION. While it is true untold scores of US are dropping out of THE COMPETITION and we are leading the People vs. Profits revolution – in COOPERATIVE CAPITALISM. However the world at large remains in the death spiral of deflation, competition, and pre set up for SUPER CRASH and World War my book reports on.

World War III began in 2008 when a digital weapon was fired at Western markets and our enemies made trillions of dollars and almost destroyed the economies of the Western World. It was only a test as Kevin Freeman’s Book GAME PLAN reports about. The real use of digital weaponry is on going and the West is LOOSING that war. The public at large has no clue while they watch the Walking Dead they are actually becoming the walking dead.

The hope of cooperation is predictably fading as the G 7 meet this week. Why?

The never changing history of the world works like this:

  1. Competitive communism and capitalism consolidated wealth so that 99% of all wealth is concentrated in the hands of a 1% elite class.
  2. This economic condition is unstable and creates a system melt down made more vulnerable in digital era’s when digital weapons are fired at the weakened system.
  3. An extended period of trade war and division between nations enlarged global tension based on markets of distrust and negotiation.
  4. A contagion event from the much more unstable economic system creates a world wide SUPER CRASH and the deflation death spiral started in step 2 continues in a whirl pool of bad debt working its way through delivering the entire world system.
  5. Economics and demographics are rebalanced through a world war that follows.

As this system never changes it might be wise to CHANGE THE SYSTEM that brings us these five results that never change or vary. To repeat these results is INSANE.

The solution is cooperative capitalism. Although there is limited time to repair the abuse of the system over 70 years. The DEFLATION DEATH SPIRAL is now entrenched in the world. Despite 100 trillion dollars being placed into the system in eight years, since 2008, the system is not INFLATING the system is DEFLATING. Why. Two reasons – competitive capitalism and socials and bad debt. They go together actually.

The following solutions would derail the pattern into world war:

  1. Establish a three year G 100 ECONOMIC CONSTITUTIONAL CONGRESS to develop a GLOBAL frame work for world trade, regulations, and security regulations with anti speculation law criminalizing lack of transparency and breach of the constitution for the world “economically”. New Box Top rules.
  2. Merge the Central Banks ( a failed model in a digital world ) back into their sovereign nation treasuries and establish a GLOBAL BANK Of last resort under the Constitution top rules – no nation would pay interest to print it’s own money.
  3. The Global Economic Constitution while celebrate diversity and sovereignty will ushering in a slow transformation into COOPERATIVE CAPITALISM – fully transparent, fully accountable, fully reportable, with zero secrets in the financial system top to bottom bottom to top.
  4. Cooperative capitalism resides within consumption flat rate taxes with no income tax in nations.
  5. All nations rebalance their budgets and refinancing all debt and infrastructure needs in SUPER BONDS fostering in the asset of TIME where SUPER SOVEREIGN NATION AND STATE BONDS refinance all existing debt and new infrastructure 25 year needs with 200 year BONDS. Time heals all wounds.

Bad debt defaults if we do nothing which is historic  and all the worlds lenders lose money because the loss is real. We stop lying in the system. There is over 100 trillion of bad debt that makes the world order financial system bankrupt today as it always becomes in depressions and deflation. There is no way to pay off the bad  debt of 70 years of credit abuse . Or with SUPER BONDS using TIME – can we reframe the problem? Should we at least study one fresh set of economics to preclude world war this time?

This model requires a choice. A decision to proclaim the present world orders are not working for anyone and a new fresh world order approach is required for all of us – where the G 100 COOPERATE vs COMPETE. These concepts out set forth in REDEMPTION THE COOPERATION REVOLUTION for world leaders and ecumenist the stuff of Nobel Prize Awards – where the world stops trying to deal with a failed system and builds a new smart entirely reformed system model that works better for all of us. Three years on the Big Island of Hawaii half way to everywhere in the world – with Aloha and lower political influence – so the Constitutional Economic Conference can complete its three year mission for the new BOX TOP RULES all nations then adopt or reject as we come together.

Today what is happening in the elite G 7 meeting in Japan? The world is working down my 1 to 5 list above in unerring forge into world war. The world war will create resolutions for short term problems. For example:

  1. Japan 25 years in Deflation with no hope of restoring its economy in real terms distracts its people by focusing their highly nationalistic country on the threat from China.
  2. China in its own death spiral of DEFLATION and utter and complete failure of the communism economic model – distracts its people from riot and killing the leading elite – by focusing the attention of the nation on war with the USA and Japan.
  3. Russian in a death spiral economically of its own failed communist system, distracts its nation from the failed economics and deflation by moving into war in the Gulf and their old provinces rattling NATO.
  4. The EU breaking apart in a failed economic model, unable to support 100 trillion in bad loans and debts, distracts its people within war with Russia as the fear and Gulf Nations a NEW CRUSADE for EUROPE.
  5. The Elite and the Economies re-inflate by killing 100’s of millions – stealing their assets – and spending 25% of GNP for nations on war with contracts back to the elite who profit from all the death and mayhem traditionally as economics rebalance through war.

This 1 to 5 is insane.

The Economic Constitutional Congress is SANE.

Competitive economics in capitalism and communism is INSANE.

Cooperative Capitalism is the final human revolution into a higher form of organization for families, institutions, communities states and nations. Redemption is the MANIFESTO for a the final REVOLUTION ….away from competition and forward into cooperation. Which will happen after the war or in the prevention of war. Inspired and Illuminated leadership is required to pull off the opportunity to move from insanity taking place at the G 7 conference.

The message for the May 20 2016 G 7 World Elite Nations Economies – ‘we can’t cooperate and agree so every nation should go forward “on their own” as we simply increase the competition forward ” . Good luck and lets go from economic war into real shooting war. Which is what follows – always.

We are in World War III.

The World War is on line and digital.

The Western Nations are loosing WORLD WAR III.

The General winning the war is President Putin. President Putin is winning the war not in the mines but in the mind. He has outfought and outthought the world leaders of today by a large measure of thinking. Lets review President Putin out front and winning World War III:

  1. He starts World War III with the digital attack on the Western nations
  2. He moves into Ukraine and reclaims ports for military expansion to the Gulf and Europe as he reclaims 100 billion in core assets now Russia’s.
  3. He secures the latest oil and gas contract the world has ever seen with China in a single deal – 3 billion dollars offsetting all sanction damage from the USA and its failing allies.
  4. He invades Syria and the without firing a bullet sends 5 million muslims with thousands of ISIS and radical terrorists into the EU forcing them to support financially when they are melting down completely in a sea of bad debt – housing, medical, food, sustainable incomes, power, water, education, jobs pulling down the entire EU without firing a bullet.
  5. Russia is arming IRAN and Korea to sustain intercontinental missiles armed with weapons of mass destruction where those nations can attack the WEST and Russia’s hands are clean while Russia destabilizes South America and Africa with communist revolutionary expansion selling its arms to both by massive billions of dollars – all the while digitally attacking the west.

The Press never see’s a whole picture and ports each grain of coffee bean but never reports the story of the COFFEE being poured by President Putin. President Putin is the most brilliant successful military and political leader of our time and commands the respect and fear of the entire world. His first aim under the Obama administration has been established, he has marginalized the USA and downsized its military and created a national joke dialogue of nations about the USA and its once upon a time powers. Everyone is laughing now at the USA.

No one is laughing about Russia. MISSION ACCOMPLISHED.

President Putin is playing Chess. The West is playing Checkers saying King me King me. Everyone is laughing while President Putin coordinates alliances and moves one up and one over with the USA so far behind …..he himself risks health issues from scream laughing himself to sleep. He must never be able to stop laughing saying over and over…can it really be so easy and are they really THAT STUPID ….I mean really?

Abraham Lincoln said so well – that we never had to fear some artificial giant would span the two oceans and arrive to threaten our doorstep in America. NO. He proclaimed the danger to America would only come from ourselves. It would an inside job. Where freedom is handed over to replace fear where we only receive more fear.

Watching financial history play out just like it did with Hitler or Pre Hitler in World War I is so interesting for these reasons:

  1. The core play book is all economics.
  2. War is always economic.
  3. The system is the issue.
  4. Competitive capitalism and competitive socialism always lead to the 1 to 5 sequence set forth here – at least for 5,000 from Greece through Rome to now.
  5. The sequence is avoidable. Cooperative Economics fixes the fatal flaws present in competitive economic systems. The detail appears in the book REDEMPTION THE COOPERATION REVOLUTION but ten.

Why do we embrace and repeat a failed model?

Because with financial history we do not retain the historic landmarks. We forget. Every generation experiences the same old thing as if it was a child happening to THEM for the very first time. It is a kind of insanity.

Education has failed us by not raising the bar on this beyond refute historic economic data. As an investment banker economist, now old enough to see these trends repeat myself, I must say I retain great hope for the generations coming up to figure this out and for every improve the system.

The FRESH MODELING set forth here represents a final economic revolution that will reset the pattern for unborn generations. What we require is illuminated and inspired leadership who embrace cooperation and desire simply a “better way” for all.

The G 7 mantra this weekend – everyone go it alone – go  your own way – break up and compete – assures the final march to SUPER CRASH and world war is all now entrenched as the elite calling the shots fail to appreciate President Putin is winning World War III by creation this competition over cooperation. To win we must win in our minds and see the game pieces and game board as it really is. We can then call CHECK on President Putin and ask him to join the Cooperation.

The present stupidity is not working although the worlds Elite will make fortunes o the misery of the coming SUPER CRASH and WORLD WAR. Think about it. Read Redemption. Become better informed. As Kevin Freeman suggests in GAME PLAN you had better make your OWN GAME PLAN as the world leadership is not preparing one for you.

The G 7 are electing:

  1. Everyone nation proceeds as we can not agree
  2. On a go it alone basis 
  3. Competitive to one another versus cooperative
  4. President Putin has shattered the Cooperation – another victory in the war
  5. The nations are more divided than ever – stupid stupid stupid 

So you have head the truth here. What does that feel like? Leave a comment on this blog and let us know as you share this sight with others who desire the truth. The real truth and nothing but the real truth.

CEO SPACE will host its last West Coast BUSINESS GROWTH CONFERENCE on July 24th with bonus New Law Crowd Funding Capital Skills training on July 22nd – moving for the rest of the decade to the EAST COAST. We will help those who want to be creating a SAFE HARBOR to prosper in any and every possible forward market to have the skills, the new resources and circles to better do so will register their family this May for our July conference serving the entire world. July is a family value forum where families wait a year to bring their children to CEO SPACE. If you enroll in May you save. Think about swapping a tax dollar for a guarantee profit – check out the details with our Chapter Presidents world wide serving 140 nations over 30 years of excellence for CEO business owners small mid size and top tier.

Redemption – its always a personal choice – and its alway sup to you.

Berny Dohrmann – Chairman CEO SPACE keeping a light on just for you today


PS: You can Checkmate EMPEROR PUTIN so he wins in the Check Mate but you must install the winning box top rules sooner than later.

IN THE RED May 19th




So the stock market – down 100’s of points this week – when everyone said the market would go “UP” ….but “me”….I said the market would dive and I told you WHY. I told you to get out of the market. I told you investors in the market have made zero over two years and that you would loose principle. Now you have. I’ve said the fourth longest recovery in 100 years with average recovery 30 months into recession corrections – can NOT CONTINUE. A recession must follow this record long recovery. This falls under never failing financial history without all the data you have in my blogs which makes the recession idea worse. The longer the expansion the more deep is the recession to follow. Again this falls under the financial economist PhD of the word …DUHHHHH?

So those who would fall into a SUCKERS rally or a FOOLS RALLY will quickly be parted with their money – moaning and so forth. The free money ride is going to end. The 2.7 Trillion not placed in growth plants equipment and expansion but speculative rigging stock prices through massive never in history before STOCK BUY BACKS is not going to sustain market prices. Everyone is gong to loose.

Real Estate is wobbling. New home listings feel during the busiest period of the year. There are many other troubling signs in real estate – namely – that 80% of first time home owners fail to credit qualify for the current price loads of first time home median prices. This means the market is UNSUSTAINABLE. Nothing not even idiot credit can make a dent in this reality. Home prices must fall until buyers in mass can afford to buy them like any commodity.

Oil went down. The experts said no way. I said in my blog WAY. Who what right? Again the predictions made here are RIGHT to an accuracy level that professionals and press follow this blog in nations all over the world. Investors use this blog as one source of data against which to make plans.

I believe the EU is hopeless economically due to trillions in bad debt and the EU must fall apart. The EU is a failed economic model. Greece will default and exit. Russia will alliance with socialist Greece and Check mate Nato. The British will exit the EU. The entire EU will crumble. The markets will be a mess until things rebalance. The Bad Debts must still be accommodated. Defaults like Puerto Rico will move to States like Illinois and California moving into Bankruptcy. China will ultimately default on enormous debt loads. The market is going to move into decades of DEFLATION and DELEVERAGING as the global system headed by failed central bank policy needs a revision are core. All central banks need to MERGE INTO THEIR RESPECTIVE treasuries.

Super Bonds or 200 year bonds inserting the missing asset of forward tax base and younger demographics, need to download the asset of “TIME ITSELF” into a new class of sovereign state and nation bonds – SUPER BONDS – and widely issue these bonds to pay off central bank obligations moving national debt forward 200 years in time. The restructured debt places nations in the RED into the BLACK and rebalances economic forward structures without world war.

A G 100 Economic Constitutional Congress needs to be convened to establish fair and equitable trading and regulatory box top rules for the entire world – all at once – versus – piece meal laws when all trading is shadow banking and in the cloud. Removing the transfer of wealth from the needy to the greedy will rebalance world accounts for 100’s of year and protect a NEW WORLD ORDER that is based on COOPERATIVE CAPITALISM not COMPETITIVE CAPITALISM. This shift will bring effortless abundance to all of us. Without it we’ll have depression and world war as we always do.

Will be wake up in time ?

We’ll see. We’ll keep a light on for ya.

Berny Dohrmann – CEO SPACE July 24th Vegas