products, the insurance benefit precipitously declines over the life of the plan. The longer the
investment is held, the lower the insurance benefit. The offering materials and the Investor
Application only reflect the overall insurance benefit and do not disclose the fact that this
amount of coverage will decline over time. The Defendants do not provide investors with a copy
of the individual insurance policies.
Cornide and de la Riva’s Misappropriation and Misuse of Investor Funds
Documents obtained from the Defendants show that from 1999 to the present,
Cornide and de la Riva received payments from Pension Fund and PFA Assurance totaling $15
million, or about 35 percent of the $43 million in revenue the companies recorded for the same
period. Company ledgers show Cornide and de la Riva received equal payments totaling $7.5
Between 2001 and 2004, Cornide purchased three homes in Coral Gables, and one
home in the Florida Keys, valued at $3 million. De la Riva purchased two homes in Coral
Gables valued at $2 million. Documents also show that Cornide and de la Riva purchased
Pension Fund’s Coral Gables office building in the name of Shadowcreek Investments, LLC, an
entity Cornide and de la Riva own.
CLAIMS FOR RELIEF
Fraud In Violation Of Section 17(a)(1) Of The Securities Act
(Against all Defendants)
The Commission repeats and realleges paragraphs 1 through 39 of its Complaint.
The Defendants have directly and indirectly, by use of the means or instruments
of transportation or communication in interstate commerce and by use of the mails, in the offer