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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA - page 4 / 18

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and the Advisers Act occurred in the Southern District of Florida. In addition, the principal

places of businesses of all four company Defendants are in the Southern District of Florida.

Cornide and de la Riva also reside in the Southern District of Florida.

12.

The

Defendants,

directly

and

indirectly,

have

made

use

of

the

means

and

instrumentalities of interstate commerce, the means and instruments of transportation and

communication in interstate commerce, and the mails, in connection with the acts, practices, and

courses of business set forth in this Complaint.

PFA’s FRAUDULENT OFFERING

A. Overview of the Investment Plans

13.

Since at least 1999, Pension Fund has offered investment plans that purport to

have both investment and insurance components. Through sales materials and oral presentations,

Pension Fund and later PFA Assurance have promoted their investment products as retirement

trusts and described them as safer investments and more profitable than similar products because

they invest them through U.S. banks and broker-dealers that purportedly serve as trustees or

custodians for the investors’ funds.

14.

Pension Fund and PFA Assurance solicit investors, most of whom reside in

Central or South America, through a network of more than 500 sales agents who also primarily

reside in those regions. Cornide and de la Riva travel throughout Latin America to train sales

agents and the “regional directors” that supervise the agents in their respective countries.

Cornide and de la Riva also meet with prospective investors abroad and in Miami, Florida, and

participate in drafting sales and offering materials. In 2003, Cornide and de la Riva created a

Cayman Islands shell company, PFA International, purportedly to operate the plans’ sales and

marketing operations.

4

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