15. According to training materials provide to YUCATAN sales agents, agents are instructed to tell
prospective investors that the investment funds are “basically being used” to purchase ore resort
properties, indicating at least some investor funds are being pooled to provide financing for new
13. Under this Universal Lease ‘opportunity,’ investors are required to invest a minimum of $5,000
dollars to participate in the program, but they may invest any amount in excess of this minimum. The
investment funds are then wired to YUCATAN’S corporate office, which subsequently uses the funds for
17. A YUCATAN recruiter informed prospective salesmen that approximately 40 percent of all
funds coming through the Universal Lease Program will originate out of investor IRAs or other similar
12. YUCATAN’s af iliate, RHI, is responsible for marketing the YUCATAN Universal ease
Program by generating and distributing various promotional materials and brochures to YUCATAN sales
14. Although several different company brochures and promotional materials are distributed to
prospective investors, YUCATAN investors are never apprised as to the inancial condition of
YUCATAN or RHI, are never informed as to the uses of YUCATAN investment funds, and are never
16. Prospective YUCATAN investors are given the option to roll part or all of their IRA or 401K
portfolios into the Universal Lease Program, effectively replacing their existing investment holdings with
the YUCATAN investment. YUCATAN’s Universal Lease application form even provides a separate
promotional materials, investors are purportedly afforded the opportunity to select one of three separate
Universal Lease “options.” In actuality, options 1 and 2 are illusory choices, effectively leaving option 3
as sole Universal Lease Program alternative.
agents throughout the United States.
Docket No. S-03539A-03-0000
afforded financial statements reflecting the degree of solvency of either YUCATAN or RHI.
section for investors to roll their investment portfolios into YUCATAN.