2024-10-10 SEC Press pdf 187 KB 25,843 chars

"UNRECOVERABLE: Timeout During Enrichment"

Exhibit of SEC Charges Rimar Capital Entities and Owner Itai Liptz for Defrauding Investors by Making False and Misleading Statements About Use of Artificial Intelligence

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summary

Itai Royi Liptz, Clifford Todd Boro, and Rimar Capital USA, Inc. were charged with fraud and false statements in connection with an offering of Simple Agreements for Future Equity (SAFEs) for the development of Rimar Capital, LLC, and were ordered to cease and desist from violating the Securities Act, Exchange Act, Investment Advisers Act, and Investment Company Act, and imposed civil money penalties of $250,000 and $60,000 on Liptz and Boro, respectively.

paragraph

The SEC has charged Itai Royi Liptz, Clifford Todd Boro, and Rimar Capital USA, Inc. (Rimar USA) with fraud and false statements in connection with an offering of Simple Agreements for Future Equity (SAFEs) for the development of Rimar Capital, LLC (Rimar LLC). Liptz and Boro raised nearly $4 million from 45 investors by making misleading statements about the platform's features, assets under management, performance, and AI-powered application. Liptz also improperly used some of the SAFE proceeds for personal purposes. The SEC has ordered Liptz, Boro, and Rimar USA to cease and desist from violating the Securities Act, Exchange Act, Investment Advisers Act, and Investment Company Act, and imposed civil money penalties of $250,000 and $60,000 on Liptz and Boro, respectively.

narrative

Enriched metadata

Scheme: unregistered-securities (100%)
Disgorgement: $202,604

Classified unregistered-securities(confidence 100%). EDGAR detection: forms Form D/S-1· recall 41% / precision 30%. detection rule →

Extracted insights

Dollar amounts 14

$20.00M $20 million $10M–$100M
$11.00M $11 million $10M–$100M
$4.00M $4 million $1M–$10M
$4.00M $4 Million $1M–$10M
$3.73M $3.725 million $1M–$10M
$2.00M $2 million $1M–$10M
$481K $480,986 $100K–$1M
$250K $250,000 $100K–$1M
$214K $213,611 $100K–$1M
$203K $202,604 $100K–$1M
$83K $83,333 $10K–$100K
$60K $60,000 $10K–$100K

Entities 5

person Clifford Todd Boro ×2
person Itai Royi Liptz ×2
company Rimar Capital, LLC ×2
company Rimar Capital USA, Inc. ×2
agency Securities and Exchange Commission

Triples 5

Itai Royi Liptz raised nearly $4 million from 45 investors
Rimar Capital USA, Inc. is controlled by Itai Royi Liptz
Rimar Capital, LLC is state‑registered investment adviser controlled by Itai Royi Liptz
Clifford Todd Boro served as board member of Rimar Capital USA, Inc.
Commission accepted Offers of Settlement submitted by Respondents

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"UNRECOVERABLE: Timeout During Enrichment" · Source

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Extracted body text (25,843c)

UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES ACT OF 1933

Release No. 11316 / October 10, 2024

SECURITIES EXCHANGE ACT OF 1934

Release No. 101297 / October 10, 2024

INVESTMENT ADVISERS ACT OF 1940

Release No. 6745 / October 10, 2024

INVESTMENT COMPANY ACT OF 1940

Release No. 35357 / October 10, 2024

ADMINISTRATIVE PROCEEDING

File No. 3-22236

In the Matter of

Rimar Capital USA, Inc.,

Rimar Capital, LLC,

Itai Royi Liptz, and

Clifford Todd Boro,

Respondents.

ORDER INSTITUTING ADMINISTRATIVE

AND CEASE-AND-DESIST PROCEEDINGS,

PURSUANT TO SECTION 8A OF THE

SECURITIES ACT OF 1933, SECTION 21C

OF THE SECURITIES EXCHANGE ACT

OF 1934, SECTIONS 203(e), 203(f) AND

203(k) OF THE INVESTMENT ADVISERS

ACT OF 1940, AND SECTION 9(b) OF THE

INVESTMENT COMPANY ACT OF 1940,

MAKING FINDINGS, AND IMPOSING

REMEDIAL SANCTIONS AND A CEASE-

AND-DESIST ORDER

The Securities and Exchange Commission (“Commission”) deems it appropriate and in the

public interest that public administrative and cease-and-desist proceedings be, and hereby are,

instituted pursuant to Section 8A of the Securities Act of 1933 (“Securities Act”), Section 21C of

the Securities Exchange Act of 1934 (“Exchange Act”), Sections 203(e), 203(f) and 203(k) of the

Investment Advisers Act of 1940 (“Advisers Act”), and Section 9(b) of the Investment Company

Act of 1940 (“Investment Company Act”) against Itai Royi Liptz (“Liptz”), Rimar Capital USA,

Inc. (“Rimar USA”), Rimar Capital, LLC (“Rimar LLC”), Clifford Todd Boro (“Boro”, and

together with Liptz, Rimar USA and Rimar LLC collectively, “Respondents”).

II.

In anticipation of the institution of these proceedings, Respondents have submitted Offers

of Settlement (the “Offers”) which the Commission has determined to accept. Solely for the

purpose of these proceedings and any other proceedings brought by or on behalf of the

Commission, or to which the Commission is a party, and without admitting or denying the findings

herein, except as to the Commission’s jurisdiction over them and the subject matter of these

proceedings, which are admitted, and except as provided herein in Section V as to Respondents

Liptz and Boro, Respondents consent to the entry of this Order Instituting Administrative and

Cease-and-Desist Proceedings, Pursuant to Section 8A of the Securities Act of 1933, Section 21C

of the Securities Exchange Act of 1934, Sections 203(e), 203(f) and 203(k) of the Investment

Advisers Act of 1940, and Section 9(b) of the Investment Company Act of 1940, Making Findings,

and Imposing Remedial Sanctions and a Cease-and-Desist Order (“Order”), as set forth below.

III.

On the basis of this Order and Respondents’ Offers, the Commission finds1 that:

Summary

1. This matter concerns fraudulent conduct related to an offering of Simple

Agreements for Future Equity (“SAFEs”)2 in a holding company, Rimar USA, controlled by Liptz,

as well as false and misleading statements by and about state-registered investment adviser, Rimar

LLC, which Liptz also controlled. Between May 2022 and April 2023, Liptz, through Rimar USA

and with the help of Rimar USA board member Boro, raised nearly $4 million from 45 investors

for the development of Rimar LLC, an adviser that purported to use artificial intelligence to

perform automated trading for advisory client accounts in a range of products including equities,

futures, and crypto assets, through a series of misrepresentations about the platform’s features, its

assets under management, its performance, and its supposed artificial intelligence-powered

application. These same misrepresentations were also made in order to obtain advisory clients,

many of whom became clients after investing in the SAFEs. Liptz also improperly used some of

the SAFE proceeds for personal purposes.

Respondents

2. Rimar Capital USA, Inc. (“Rimar USA”) is a corporation organized in Delaware

on May 13, 2022, wholly-owns Rimar LLC, and serves as its Managing Member. Its principal

place of business is Liptz’s private residence in Burlingame, California. It is controlled by Itai Royi

1 The findings herein are made pursuant to Respondents’ Offers of Settlement and are not binding on any

other person or entity in this or any other proceeding.
2 A SAFE is a securities agreement between an investor and the company in which the company generally

promises to give the investor a future equity stake in the company if certain trigger events occur.

Liptz, who serves as its CEO; Rimar USA does not own any investment securities. Liptz and

Clifford Todd Boro own approximately 93% and 5%, respectively, of Rimar USA.

3. Rimar Capital, LLC (“Rimar LLC”) is a limited liability company organized in

Delaware on May 4, 2020. Rimar LLC is registered as an investment adviser with the State of

California on June 10, 2021, and with the states of New York in 2022 and Florida in 2023. Its

principal place of business is likewise Burlingame, California. Liptz serves as its investment

manager and CCO; it is wholly-owned by Rimar USA. According to its Form ADV filed on March

11, 2023, Rimar LLC has regulatory assets under management of approximately $4 million.

4. Itai Royi Liptz (“Liptz”), age 38, is a resident of Burlingame, California and an

Israeli and South African citizen. Liptz passed the Securities Industry Essentials examination and

holds Series 63 and 65 licenses. He is the sole employee of Rimar LLC and Rimar USA and

controls both firms.

5. Clifford Todd Boro (“Boro”), age 54, is a resident of San Diego, California. Boro

is a director and consultant to Rimar USA and was involved in identifying and soliciting potential

investors in SAFEs.

Background

6. According to its marketing materials, Rimar LLC purports to be an advisory firm

that offers a range of automated trading strategies through its platform with strategies purportedly

driven by the use of artificial intelligence. Liptz was the only investment manager at Rimar LLC

and was entitled to receive compensation as owner and CEO of Rimar LLC and Rimar USA. By

mid-2023, Rimar LLC said it had 54 clients which it advised as to security futures trading.

Contrary to the firm’s marketing materials, the firm has never and does not currently offer its

clients trading services related to stocks, bonds, crypto assets.

7. Between 2022 and 2023, ostensibly in an effort to develop the Rimar LLC

platform, Liptz and Boro engaged in the SAFE offering through Rimar USA. Pursuant to the

SAFE’s terms, investors would get equity in Rimar USA in the event of any equity financing and

would receive a share of proceeds upon a liquidity event, such as an initial public offering.

Throughout the fundraising period, Liptz and Boro disseminated a variety of marketing materials

to prospective investors, including several pitch decks. Rimar USA identified prospective investors

through Liptz’s and Boro’s connections, who they primarily contacted via email and in-person

meetings. Liptz was responsible for approving the content in the marketing materials, such as the

pitch decks and posts. Boro relied on Liptz for the accuracy of the information that he transmitted.

Boro received a monthly consulting fee during the relevant period when he was spearheading the

effort to find SAFE investors.

8. In total, Rimar USA raised $3.725 million from 45 investors. According to the pitch

decks disseminated to some prospective investors in the SAFEs, the proceeds were intended to be

used for “additional engineering,” “compliance,” development of an app, and sales and marketing

of the adviser.

A. Liptz, Boro, and Rimar USA Raised Almost $4 Million for SAFE Investments

Through Misleading Statements to Investors

9. The marketing materials and communications with investors disseminated to

prospective investors in SAFEs by Liptz and Boro contained a range of false and misleading

statements regarding Rimar LLC. Liptz knew or was reckless in not knowing they were

misstatements given his control over the company, and Boro should have known they were

misstatements had he exercised reasonable care as a board member.

Overstated Assets Under Management

10. During the SAFE fundraising, Liptz and Boro, through Rimar USA, made

numerous misrepresentations in pitch decks, online posts in a members-only investment group and

emails about Rimar LLC’s assets under management (“AUM”), repeatedly claiming the AUM was

between $16 and $20 million, suggesting an established base of advisory clients, when in reality,

the amount was much less.

11. About three quarters of the SAFEs were entered into in 2022, at which time Rimar

LLC actually had less than $2 million in AUM. In March 2023, Rimar LLC’s AUM hit its high of

$11 million, which it maintained only for another month. In reality, the advertised AUM did not

relate to Rimar LLC, but instead included the assets of several entities overseas (“Overseas

Entities”), which Liptz knew were not controlled by Rimar LLC. Neither Liptz nor Rimar LLC

provided any advisory services to the Overseas Entities.

Exaggerated Technological Capabilities and Never Implemented AI-Client Application

Interface

12. Liptz and Boro, through Rimar USA, also made false and misleading claims in

pitch decks, online posts in a members-only investment group, and emails about the expansive

technological operations of Rimar LLC. This included claims about an extensive infrastructure of

coders and data processing capabilities, which were misleading given that they referred to the

operations of the Overseas Entities, in which neither Rimar USA nor Rimar LLC had any

ownership interest. The marketing materials and solicitation communications also repeatedly

referred to Rimar LLC as having an artificial intelligence-driven platform for trading, among other

products, stock and crypto assets. But the firm had no trading application at all at the time of the

fundraising, and has never had a trading platform for stock or crypto assets.

13. As with the claims about AUM, Rimar LLC’s overstated claims about its

technology conflated technology apparently owned by Overseas Entities, not Rimar LLC itself.

Hedge Fund Structure Not Created

14. In connection with Rimar USA’s SAFE fundraising, Liptz and Boro also

misrepresented that Rimar LLC was managing a “hedge fund,” when in fact the only clients of the

Rimar LLC at the time were separately managed accounts.

Misleading Claims about Performance

15. During the fundraising, Liptz and Boro also made numerous misleading statements

to prospective investors in SAFEs concerning Rimar LLC’s managed client account performance.

In some instances, Rimar USA’s pitch decks contained performance tables that had monthly

returns from January 2015 through December 2022. In other instances, the decks contained

snapshots of returns, such as “46% CAGR [compound annual growth rate] since 2015” or “In

2022, Rimar is up 23%”.

16. As with several of the misleading claims discussed above, the claims about the

returns were misleading because the figures did not represent the returns of Rimar LLC, but rather

the returns of the separate Overseas Entities, a fact that was not disclosed to prospective investors.

17. The marketing materials indicated they contained three months of actual returns

(from October through December 2022), which were supposedly on the returns of accounts of

Rimar LLC’s clients. The advertised returns for these months were -3.22%, 20.55%, and 5.91%.

Yet despite the claims otherwise, the returns appear to be derived instead from a single account in

the name of Rimar LLC, not the accounts it managed for its clients.

18. For these supposed actual returns, Rimar LLC engaged an accounting firm to verify

its returns (again only as to the one proprietary account, not to the client accounts). Even under the

accounting firm’s analysis, the report calculated returns gross of all fees. Rimar USA’s

promotional materials, by contrast, claimed the returns were net of all fees.

B. Rimar LLC and Liptz Obtained Advisory Clients Through Fraudulent

Statements

19. In addition to obtaining investors in SAFEs using misleading marketing materials,

Liptz also obtained advisory clients of Rimar LLC using the same misleading claims. Of the 45

different investors in SAFEs, at least 20 also became advisory clients. Liptz and Boro disseminated

Rimar USA’s SAFE marketing materials to prospective Rimar LLC clients, as well as other pitch

decks, and many of the email communications described above included invitations to become

Rimar LLC clients. When soliciting the SAFE investments, Liptz and Boro provided an incentive

that, if the individual invested in SAFEs, the investor would be entitled to become an advisory

client at half the regular management fee.

20. At or around the time of the Rimar USA SAFE fundraising, Liptz also disseminated

additional marketing materials, which were essentially shorter versions of the SAFE pitch decks,

and which he created specifically for attracting advisory clients. These marketing handouts

contained several of the same misrepresentations described above, in particular, the misleading

claims about performance and concerning the firm’s supposed technological capabilities.

C. Liptz Used Some of Rimar USA’s SAFE Proceeds for Personal Purposes

21. Liptz used a portion of the proceeds raised from the SAFE investments for personal

purposes that deviated from what investors were told or understood to be the purpose of the

fundraising. The SAFE marketing materials had varied descriptions of the use of proceeds. The

final version of the pitch deck stated the fundraising was for “additional engineering needs” and

“to scale compliance.” Other marketing materials described that the proceeds would be used for a

“Hedge Fund for everyone app” and “Using funds for US launch” and earlier drafts identified uses

of 25% for app development and 75% for building and scaling sales and marketing. Neither the

agreement nor the marketing materials ever disclosed that Liptz was authorized to use the proceeds

for personal expenses. Rimar USA’s funds were sometimes transferred to Rimar LLC, and Liptz

similarly charged Rimar LLC’s bank account (whose proceeds were sourced from Rimar USA and

from advances of working capital from Liptz) for personal expenses.

22. Before and during the time frame of the SAFE fundraising Liptz made capital

advances to Rimar USA and Rimar LLC of which $480,986 was outstanding as of June 30, 2024.

23. In connection with the Enforcement staff’s investigation, in July 2024, Rimar USA

adopted a board resolution offsetting $213,611.25 in Liptz’s personal charges expensed to Rimar

USA and Rimar LLC against capital advances Liptz previously made. The $213,611.25 represents

$202,604 in personal charges expensed to Rimar USA and Rimar LLC and prejudgment interest of

$11,007.25.

Violations

24. As a result of the conduct described above, Rimar USA committed violations of

Section 17(a) of the Securities Act and Section 10(b) of the Exchange Act and Rule 10b-5

thereunder, which prohibit fraudulent conduct in the offer or sale of securities and in connection

with the purchase or sale of securities.

25. As a result of the conduct described above, Rimar LLC willfully violated

Sections 206(1) and 206(2) of the Advisers Act, which prohibit fraudulent conduct by an

investment adviser.

26. As a result of the conduct described above, Liptz willfully violated Section 17(a) of

the Securities Act, Section 10(b) of the Exchange Act and Rule 10b-5 thereunder, which prohibit

fraudulent conduct in the offer or sale of securities and in connection with the purchase or sale of

securities, and Sections 206(1) and 206(2) of the Advisers Act, which prohibit fraudulent conduct

by an investment adviser.

27. As a result of the conduct described above, Boro violated Sections 17(a)(2) and

17(a)(3) of the Securities Act, which prohibits fraudulent conduct in the offer or sale of securities.

Violations of Sections 17(a)(2) and 17(a)(3) may rest on a finding of simple negligence. Aaron v. SEC,

446 U.S. 680, 697 (1980). Proof of scienter is not required to establish a violation of Sections 17(a)(2)

and 17(a)(3). Id.

Disgorgement

28. The disgorgement and prejudgment interest ordered in paragraph IV.G. is

consistent with equitable principles and does not exceed Liptz’s net profits from his violations

and are deemed satisfied by offsets of his capital advances to Rimar USA and Rimar LLC in July

2024.

IV.

In view of the foregoing, the Commission deems it appropriate, and in the public interest to

impose the sanctions agreed to in Respondents’s Offers.

Accordingly, pursuant to Section 8A of the Securities Act, Section 21C of the Exchange

Act, Sections 203(e), 203(f) and 203(k) of the Advisers Act, and Section 9(b) of the Investment

Company Act, it is hereby ORDERED that:

A. Respondent Rimar USA cease and desist from committing or causing any violations

and any future violations of Section 17(a) of the Securities Act and Section 10(b) of the Exchange

Act and Rule 10b-5 thereunder.

B. Respondent Rimar LLC cease and desist from committing or causing any violations

and any future violations of Sections 206(1) and 206(2) of the Advisers Act.

C. Respondent Liptz cease and desist from committing or causing any violations and

any future violations of Section 17(a) of the Securities Act, Section 10(b) of the Exchange Act and

Rule 10b-5 thereunder, and Sections 206(1) and 206(2) of the Advisers Act.

D. Respondent Boro cease and desist from committing or causing any violations and

any future violations of Section 17(a)(2) and (3) of the Securities Act.

E. Respondent Liptz be, and hereby is:

barred from association with any broker, dealer, investment adviser,

municipal securities dealer, municipal advisor, transfer agent, or nationally

recognized statistical rating organization; and

prohibited from serving or acting as an employee, officer, director, member

of an advisory board, investment adviser or depositor of, or principal

underwriter for, a registered investment company or affiliated person of such

investment adviser, depositor, or principal underwriter;

with the right to apply for reentry after five (5) years to the appropriate self-

regulatory organization, or if there is none, to the Commission.

Any reapplication for association by the Respondent Liptz will be subject to the applicable

laws and regulations governing the reentry process, and reentry may be conditioned upon a number

of factors, including, but not limited to, compliance with the Commission’s order and payment of

any or all of the following: (a) any disgorgement or civil penalties ordered by a Court against

Respondent Liptz in any action brought by the Commission; (b) any disgorgement amounts

ordered against the Respondent Liptz for which the Commission waived payment; (c) any

arbitration award related to the conduct that served as the basis for the Commission order; (d) any

self-regulatory organization arbitration award to a customer, whether or not related to the conduct

that served as the basis for the Commission order; and (e) any restitution order by a self-regulatory

organization, whether or not related to the conduct that served as the basis for the Commission

order.

F. Respondent Rimar LLC is censured.

G. Respondent Liptz shall pay disgorgement of $202,604 and prejudgment interest of

$11,007.25 for a total of $213,611.25, with such payment being deemed satisfied by offsets

recorded in July 2024 against capital advances Liptz previously made to Rimar USA and Rimar

LLC.

H. Respondent Liptz shall pay a civil money penalty in the amount of $250,000 to the

Securities and Exchange Commission. Payments shall be made in the following installments: (1)

due within ten [10] days of the entry of this Order, $83,333.34; (2) due within forty-five [45] days

of the entry of this Order, $83,333.33; and (3) due within ninety [90] days of the entry of this

Order, $83,333.33. Payments shall be applied first to post order interest, which accrues pursuant to

31 U.S.C. 3717. Prior to making the final payment set forth herein, Respondent shall contact the

staff of the Commission for the amount due. If Respondent fails to make any payment by the date

agreed and/or in the amount agreed according to the schedule set forth above, all outstanding

payments under this Order, including post-order interest, minus any payments made, shall become

due and payable immediately at the discretion of the Staff of the Commission without further

application to the Commission.

I. Respondent Boro shall pay a civil money penalty in the amount of $60,000 to the

Securities and Exchange Commission. Payments shall be made in the following installments: (1)

due within ten [10] days of the entry of this Order, $20,000; (2) due within forty-five [45] days of

the entry of this Order, $20,000; and (3) due within ninety [90] days of the entry of this Order,

$20,000. Payments shall be applied first to post order interest, which accrues pursuant to 31 U.S.C.

3717. Prior to making the final payment set forth herein, Respondent shall contact the staff of the

Commission for the amount due. If Respondent fails to make any payment by the date agreed

and/or in the amount agreed according to the schedule set forth above, all outstanding payments

under this Order, including post-order interest, minus any payments made, shall become due and

payable immediately at the discretion of the Staff of the Commission without further application to

the Commission.

Payment must be made in one of the following ways:

(1) Respondent may transmit payment electronically to the Commission, which

will provide detailed ACH transfer/Fedwire instructions upon request;

(2) Respondent may make direct payment from a bank account via Pay.gov

through the SEC website at http://www.sec.gov/about/offices/ofm.htm; or

(3) Respondent may pay by certified check, bank cashier’s check, or United

States postal money order, made payable to the Securities and Exchange

Commission and hand-delivered or mailed to:

Enterprise Services Center

Accounts Receivable Branch

HQ Bldg., Room 181, AMZ-341

6500 South MacArthur Boulevard

Oklahoma City, OK 73169

Payments by check or money order must be accompanied by a cover letter identifying

Respondent's name as a Respondent in these proceedings, and the file number of these

proceedings; a copy of the cover letter and check or money order must be sent to Brent Wilner,

Esq., Associate Regional Director, Division of Enforcement, Securities and Exchange

Commission, 444 South Flower Street, 9th Floor, Los Angeles, CA.

J. Pursuant to Section 308(a) of the Sarbanes-Oxley Act of 2002, a Fair Fund is created

for the penalties referenced in paragraphs H and I above. Amounts ordered to be paid as civil

money penalties pursuant to this Order shall be treated as penalties paid to the government for all

purposes, including all tax purposes. To preserve the deterrent effect of the civil penalty,

Respondents Liptz and Boro agree that in any Related Investor Action, they shall not argue that

they are entitled to, nor shall they benefit by, offset or reduction of any award of compensatory

damages by the amount of any part of Respondents’ payment of a civil penalty in this action

(“Penalty Offset”). If the court in any Related Investor Action grants such a Penalty Offset,

Respondents Liptz and Boro each agree that they shall, within 30 days after entry of a final order

granting the Penalty Offset, notify the Commission's counsel in this action and pay the amount of

the Penalty Offset to the Securities and Exchange Commission. Such a payment shall not be

deemed an additional civil penalty and shall not be deemed to change the amount of the civil

penalty imposed in this proceeding. For purposes of this paragraph, a “Related Investor Action”

means a private damages action brought against Respondents Liptz and Boro by or on behalf of

one or more investors based on substantially the same facts as alleged in the Order instituted by the

Commission in this proceeding.

http://www.sec.gov/about/offices/ofm.htm

It is further Ordered that, solely for purposes of exceptions to discharge set forth in Section

523 of the Bankruptcy Code, 11 U.S.C. §523, the findings in this Order are true and admitted by

Respondents Liptz and Boro, and further, any debt for disgorgement, prejudgment interest, civil

penalty or other amounts due by Respondents Liptz or Boro under this Order or any other

judgment, order, consent order, decree or settlement agreement entered in connection with this

proceeding, is a debt for the violation by Respondents Liptz or Boro of the federal securities laws

or any regulation or order issued under such laws, as set forth in Section 523(a)(19) of the

Bankruptcy Code, 11 U.S.C. §523(a)(19).

By the Commission.

Vanessa A. Countryman

Secretary

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