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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO. 05-20863-CIV-MOORE

SECURITIES AND EXCHANGE COMMISSION,

Plaintiff,

v.

PENSION FUND OF AMERICA L.C., PFA ASSURANCE GROUP, LTD., PFA INTERNATIONAL, LTD., CLAREN TPA, LLC LUIS M. CORNIDE, and ROBERT DE LA RIVA,

Defendants.

) ) ) ) ) ) ) ) ) ) ) ) ) ) )

_______________________________________________)

COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF

Plaintiff, Securities and Exchange Commission alleges that:

INTRODUCTION

1.

The Commission brings this action to enjoin the Defendants from continuing to

defraud investors through the sale of so-called retirement trust plans issued by two companies,

Pension Fund of America L.C. (“Pension Fund”) and PFA Assurance Group, Ltd. (“PFA

Assurance”), in violation of the antifraud provisions of the federal securities laws. From at least

1999 to the present, Pension Fund, its affiliated companies, and their two principals have raised

approximately $127 million from more than 3,400 investors by offering “retirement trust plans”

that combine life insurance and investments in mutual funds issued by well-known U.S. mutual

fund companies.

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