The allegations read: Sec admin release 34-85177, february 22, 2019: the securities and exchange commission (commission) deems it appropriate and in the public interest that public administrative proceedings be, and hereby are, instituted pursuant to section 15(b) of the securities exchange act of 1934 (exchange act) against ernest j. Romer, iii (romer). Between july 30, 2018 and october 9, 2018, romer pled "no contest" to 13 counts of embezzlement in violation of michigan compiled laws 750.174, a felony, before the macomb county circuit court in people v. Ernest julius romer iii. On december 5, 2018, romer was convicted on the 13 counts of embezzlement and sentenced to 85 to 240 months in prison and ordered to pay $2,650,000 in restitution. The embezzlement counts of the criminal complaints to which romer pled no contest and to which he was convicted alleged, among other things, that as an agent, servant, or employee of certain named persons and/or being a trustee, bailee, or custodian of the property of such named persons, did convert to his own use or take or secrete with intent to convert to his own use, without consent of his principal, money or personal property of his principal having a value ranging from between $20,000 to $50,000 and/or $100,000 or more, that came into his possession or under his charge or control by virtue of his relationship with the principal.