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15. According to training materials provide to YUCATAN sales agents, agents are instructed to tell

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prospective investors that the investment funds are “basically being used” to purchase ore resort

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properties, indicating at least some investor funds are being pooled to provide financing for new

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13. Under this Universal Lease ‘opportunity,’ investors are required to invest a minimum of $5,000

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dollars to participate in the program, but they may invest any amount in excess of this minimum. The

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investment funds are then wired to YUCATAN’S corporate office, which subsequently uses the funds for

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17. A YUCATAN recruiter informed prospective salesmen that approximately 40 percent of all

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funds coming through the Universal Lease Program will originate out of investor IRAs or other similar

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12. YUCATAN’s af iliate, RHI, is responsible for marketing the YUCATAN Universal ease

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Program by generating and distributing various promotional materials and brochures to YUCATAN sales

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14. Although several different company brochures and promotional materials are distributed to

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prospective investors, YUCATAN investors are never apprised as to the inancial condition of

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YUCATAN or RHI, are never informed as to the uses of YUCATAN investment funds, and are never

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16. Prospective YUCATAN investors are given the option to roll part or all of their IRA or 401K

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portfolios into the Universal Lease Program, effectively replacing their existing investment holdings with

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the YUCATAN investment. YUCATAN’s Universal Lease application form even provides a separate

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promotional materials, investors are purportedly afforded the opportunity to select one of three separate

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Universal Lease “options.” In actuality, options 1 and 2 are illusory choices, effectively leaving option 3

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as sole Universal Lease Program alternative.

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agents throughout the United States.

Docket No. S-03539A-03-0000

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undisclosed purposes.

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afforded financial statements reflecting the degree of solvency of either YUCATAN or RHI.

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acquisitions.

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section for investors to roll their investment portfolios into YUCATAN.

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retirement accounts.

18. Under YUCATAN’s Universal Lease Program, and as represented in RHI’s associated

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