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https://www.crowdfundinsider.com/2015/07/70477-sec-issues-cease-desist-order-to-eb-5-investment-companies-for-acting-as-unregistered-broker-dealers-this-matters-to-the-crowdfunding-industry/
SEC Issues Cease & Desist Order To “EB-5” Investment Companies For Acting As Unregistered Broker-Dealers: This Matters to the Crowdfunding Industry