The allegations read: The united states securities and exchange commission alleges in its complaint that beginning in or around june 2021 through at least july 2023, retirement specialty group, inc. (rsg), a tennessee-based sec-registered investment adviser, and its principal, cookeville, tennessee resident donald anthony wright (wright) (collectively, defendants) recommended, offered, and sold over $2.4 million in fraudulent promissory notes to at least five rsg advisory clients and at least one other person. Wright raised this money, at least in part, to support his efforts to acquire a faith-based media marketing company. Specifically, several entities told wright that they could help him secure financing for this acquisition, but insisted that he first transfer certain amounts to them as a prerequisite. Lacking these funds himself, wright generated the required capital by having his advisory clients and at least one other investor purchase promissory notes supposedly issued by these entities (the note issuers). In selling these notes, wright made material misrepresentations and omissions concerning the nature and safety of the investments and the planned use of proceeds. For some investments, he misrepresented that he had invested his own money. In another instance, wright recommended and sold a note issuer's promissory notes to two clients immediately before wright obtained a loan from the note issuer. Upon information and belief, the note issuer required the sale of these notes as a prerequisite to loaning wright any money. Wright also failed to disclose his conflicts of interest to his clients; namely, wright failed to disclose that he and/or rsg had business relationships with the note issuers to help wright secure funds, including for the purchase of the faith based media marketing company, generally, and that he was recommending these notes so that he could secure financing from the note issuers to purchase the company and to otherwise obtain money, specifically. Wright also sold forged notes that purportedly were issued by one note issuer but, in reality, were issued by wright without the note issuer's knowledge or authorization. Wright did not disclose that these notes were unauthorized and forged, or that that he planned to use the note proceeds solely for his personal benefit in an attempt to obtain financing to purchase the media company and for other purposes. After defrauding investors with the sale of these notes, wright repeatedly misled them about the status of their investments and repayments. This included having the clients enter into further agreements with the note issuers and, in at least one instance, falsifying wire transfer information to mislead a client that wright would imminently have funds available to repay the client.