The allegations read: The securities and exchange commission (the "commission"), for its complaint against levin, alleges that levin violated the requirement that persons engaging in the business of effecting securities transactions for others be registered by soliciting over $2.6 million from at least 27 investors from 2017 through 2018, without being registered. This conduct brought levin within the statutory definition of a broker. As a result, levin was required to register with the commission under section 15(a) of the securities exchange act of 1934 ("exchange act"). Despite not having a brokerage license, levin solicited investors, primarily in texas, to purchase units of the crp automotive portfolio, lp (the "crp fund"), which levin established through another entity he controlled, comprehensive retirement planning, llc ("crp llc"). The crp fund then invested investor funds in a separate funds controlled by a new york-based alternative asset management firm, gpb capital, inc. ("gpb capital"). By virtue of the conduct alleged herein, levin has engaged in acts, practices, transactions and courses of business that constitute violations of section 15(a) of the exchange act, 15 u.s.c. \\u00a7 78o(a).