UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES ACT OF 1933

Release No. 10855 / September 28, 2020

SECURITIES EXCHANGE ACT OF 1934 

Release No. 90026 / September 28, 2020

ADMINISTRATIVE PROCEEDING

File No. 3-20087

In the Matter of

Raymond Allan Fine,

Respondent.

ORDER INSTITUTING 

ADMINISTRATIVE AND CEASE-ANDDESIST PROCEEDINGS PURSUANT TO 

SECTION 8A OF THE SECURITIES ACT 

OF 1933 AND SECTIONS 15(b) AND 21C 

OF THE SECURITIES EXCHANGE ACT 

OF 1934, MAKING FINDINGS, AND 

IMPOSING A CEASE-AND-DESIST 

ORDER 

I.

The Securities and Exchange Commission (“Commission”) deems it appropriate that

administrative and cease-and-desist proceedings be, and hereby are, instituted pursuant to Section 

8A of the Securities Act of 1933 (“Securities Act”) and Sections 15(b) and 21C of the Securities 

Exchange Act of 1934 (“Exchange Act”), against Raymond Allan Fine (“Fine” or “Respondent”). 

II.

In anticipation of the institution of these proceedings, Fine has submitted an Offer of 

Settlement (the “Offer”) which the Commission has determined to accept. Solely for the purpose 

of these proceedings and any other proceedings brought by or on behalf of the Commission, or to 

which the Commission is a party, and without admitting or denying the findings herein, except as 

to the Commission’s jurisdiction over him and the subject matter of these proceedings, which are 

admitted, and except as provided herein in Section V, Fine consents to the entry of this Order

Instituting Administrative and Cease-and-Desist Proceedings Pursuant To Section 8A of the

Securities Act of 1933 and Sections 15(b) and 21C of the Securities Exchange Act of 1934, 

Making Findings, and Imposing a Cease-and-Desist Order (“Order”), as set forth below. 
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III.

On the basis of this Order and Fine’s Offer, the Commission finds1that: 

Summary

1. This matter concerns violations of the federal securities laws by Raymond Allan 

Fine in connection with three oil and gas drilling projects conducted by Crudefunders, LLC 

(“Crudefunders”), an unregistered, online equity crowdfunding portal. Between July 2014 and 

July 2017, Fine was one of the owners and managers of Crudefunders, which conducted several 

securities offerings through telephone solicitations and its web site, www.crudefunders.com. 

2. Fine violated Sections 17(a)(2) and 17(a)(3) of the Securities Act by making 

undisclosed withdrawals from investor funds in order to pay for Crudefunders’ business operations 

and provide compensation for himself and other Crudefunders employees. Fine also violated 

Securities Act Sections 5(a) and 5(c) by offering and selling unregistered securities that did not 

qualify for an exemption, and violated Exchange Act Section 15(a) by acting as an unregistered 

broker-dealer in connection with three of Crudefunders’ offerings.

Respondent

3. Raymond Allan Fine, age 46, resides in Reading, Massachusetts. Fine has never 

held any securities licenses and has never been registered with the Commission in any capacity. 

Fine was a principal of Crudefunders and served as one of its officers and managers from July 17, 

2014, until he resigned from the company on July 17, 2017.

Other Relevant Entity

4. Crudefunders, LLC is a privately owned, Texas-based limited liability company 

that was incorporated in Texas on July 17, 2014. From early 2015 until early 2019, Crudefunders 

operated www.crudefunders.com through which it collected information about potential investors 

and sold securities related to oil-drilling projects. Crudefunders has never been registered with the 

Commission in any capacity. Crudefunders substantially ceased its operations and terminated its 

website in or about early 2019.

The Morbitzer #1 Offering

5. Between April 2015 and June 2017, Crudefunders, primarily through two sales 

agents, raised approximately $525,000 from fifteen investors through the unregistered sale of 

securities for an oil drilling project called “Morbitzer #1.” The sales agents solicited investments 

 

1 The findings herein are made pursuant to Fine’s Offer of Settlement and are not binding on any other person or 

entity in this or any other proceeding. 
3

in the project by calling individuals who had provided their contact information to Crudefunders

through its website or at in-person marketing events.

6. Under Fine’s control, the sales agents distributed an informational circular and 

subscription agreement about Morbitzer #1 to potential investors. The circular stated that investors 

in Morbitzer #1 would collectively receive a 75% working interest in the well, and projected that 

the well would produce 50 to 150 barrels of oil per day. The circular indicated that investors could 

receive a return ranging from zero (if the well did not produce oil) to $458,814 per $50,000 unit, 

and contained a summary projecting that investors would receive a total return of $225,625 per

unit, representing a 450% return on investment, based on a projected oil price of $70 per barrel and 

production of 100 barrels per day. The materials sent to investors did not disclose that 

Crudefunders and its employees would receive commissions or other payments from investor 

funds.

7. Though Crudefunders employees requested that some investors answer written

questions about their income or net worth, neither Fine nor anyone else at Crudefunders requested

documentation to determine whether investors were accredited before permitting them to invest in 

Morbitzer #1. At least two individuals who invested in Morbitzer #1 did not qualify as accredited 

investors. Neither Fine nor anyone else at Crudefunders submitted filings to the Commission 

related to Morbitzer #1.

8. On behalf of Crudefunders, Fine controlled the accounts which held the funds 

submitted by Morbitzer #1 investors. Fine withdrew approximately $110,000 from those accounts

to pay for Crudefunders’ business expenses unrelated to Morbitzer #1 and to issue payments to 

himself and commissions to other Crudefunders employees. These payments and commissions

were not disclosed in the Morbitzer #1 offering circular or subscription agreements. The Morbitzer 

#1 well was ultimately drilled, but the project was abandoned after an oil exploration company 

determined that the well did not contain commercially viable quantities of hydrocarbons. 

Online Securities Offerings

9. Between August 2016 and May 2017, Crudefunders, primarily under Fine’s 

direction, carried out two securities offerings through its website, which were referred to as

“Aquinas TL-Smith #25” and “Mesa-Marshall #1-2.” Crudefunders promoted these projects as 

offerings pursuant to Regulation Crowdfunding and marketed them to retail investors. Information 

about these offerings, including offering circulars, brochures, subscription agreements, and 

informational videos were freely available to anyone who visited Crudefunders’ web site. The

offering materials for Aquinas TL-Smith #25 predicted total investment returns of 239%, but noted 

that the projections were not a guarantee of the actual results of the project. The offering materials 

for Mesa Marshall #1-2 stated that the “expected” returns from the project were 328%, but also 

noted that investors could lose their full investment if the wells were subsequently found not to 

contain viable quantities of hydrocarbons.

10. For these offerings, Fine negotiated agreements with oil exploration companies to 

offer its investors a portion of the working interest of an upcoming oil-drilling project. Fine also 

directed the creation of the business entities that served as the issuers for the offerings, submitted 
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relevant filings to the Commission, and oversaw the use of investor funds after target amounts 

were raised. As compensation, Crudefunders received an up-front “Portal Preparation [and] 

Listing Fee” from the oil exploration company connected to each project, and also received a 

working interest in each of the projects after they successfully funded. During this period of time, 

neither Fine nor any other employee of Crudefunders was registered as a broker-dealer or 

associated with a registered broker-dealer. 

11. Even though Fine and Crudefunders were primarily responsible for creating and 

promoting the offerings, the offering materials created by Crudefunders identified a registered 

broker-dealer as the intermediary for each of the offerings. Crudefunders did maintain a service 

agreement with the broker-dealer, but the broker-dealer’s role in the offerings was limited to 

investor eligibility verification, review of due diligence and offering materials, holding investor 

funds before the target offering amounts were raised, and limited compliance support, and it did 

not play a substantial role in promoting the offerings or soliciting investors. Crudefunders raised 

$359,000 collectively for Aquinas TL-Smith #25 and Mesa-Marshall #1-2. In total, the projects 

generated returns less than $5,000 for investors in these offerings.

Violations

12. As a result of his conduct in the Morbitzer #1 offering, Fine:

violated Section 17(a)(2) of the Securities Act, which makes it unlawful in the offer 

or sale of securities to obtain money or property by means of any untrue statement 

of a material fact or any omission to state a material fact necessary in order to make 

the statements made, in light of the circumstances under which they were made, not 

misleading;

violated Section 17(a)(3) of the Securities Act, which proscribes, in the offer or sale 

of securities, any transaction, practice or course of business which operates or 

would operate as a fraud or deceit upon a purchaser of securities; 

willfully violated Section 5(a) of the Securities Act, which prohibits the sale of 

securities through interstate commerce or the mails unless a registration statement is 

in effect; and

willfully violated Section 5(c) of the Securities Act, which prohibits any offer to 

sell any security through interstate commerce or the mails unless a registration 

statement has been filed as to such security with the Commission.

13. As a result of his conduct in the Morbitzer #1, Aquinas TL-Smith #25, and MesaMarshall #1-2 offerings, Fine willfully violated Section 15(a)(1) of the Exchange Act, which 

provides that, absent an exception or exemption, it is unlawful for any broker or dealer “to make 

use of the mails or any means or instrumentality of interstate commerce to effect any transactions 

in, or to induce or attempt to induce the purchase or sale, of any security . . . unless such broker or 

dealer is registered in accordance” with Section 15(b) of the Exchange Act. 
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Disgorgement and Civil Penalties

14. Fine has submitted a sworn Statement of Financial Condition dated April 19, 2020,

and other evidence and has asserted his inability to pay disgorgement, prejudgment interest, and a 

civil monetary penalty. 

IV.

In view of the foregoing, the Commission deems it appropriate to impose the sanctions 

agreed to in Fine’s Offer.

Accordingly, it is hereby ORDERED that:

A. Pursuant to Section 8A of the Exchange Act and Section 21C of the Exchange Act, 

Fine cease and desist from committing or causing any violations and any future violations of 

Sections 17(a)(2), 17(a)(3), 5(a), or 5(c) of the Securities Act, or Section 15(a)(1) of the Exchange 

Act.

B. Pursuant to Section 15(b)(6), Fine be, and hereby is, barred from association with 

any broker, dealer, investment adviser, municipal securities dealer, municipal advisor, transfer 

agent, or nationally recognized statistical rating organization, or from participating in an offering of 

penny stock.

C. Fine shall pay disgorgement of $110,000 and prejudgment interest of $17,263.05, 

but payment of such amount except for $21,000 is waived based upon Fine’s sworn 

representations in his Statement of Financial Condition dated April 19, 2020, and other 

documents submitted to the Commission. Payment shall be made in the following installments: 

$7,000 within 14 days of the entry of this Order; $7,000 within 365 days of the entry of this Order; 

and $7,000 within 730 days of the entry of this order. Payments shall be applied first to post-order 

interest, which accrues pursuant to SEC Rule of Practice 600. Prior to making the final payment 

set forth herein, Fine shall contact the staff of the Commission for the amount due. If Fine fails to 

make any payment by the date agreed and/or in the amount agreed according to the schedule set 

forth above, all outstanding installment payments under this Order, including post-order interest, 

minus any payments made, shall become due and payable immediately at the discretion of the staff 

of the Commission without further application to the Commission.

D. A Distribution Fund shall be created for the funds paid as referenced in IV.C. This 

Distribution Fund may be added to or combined with the distribution fund created in In the Matter 

of David Taylor (AP File No. 3- 20088) in order for the combined distribution funds to be 

distributed to harmed investors affected by the same violative conduct at issue in this proceeding.

E. Based upon Fine’s sworn representations in his Statement of Financial Condition 

dated April 19, 2020, and other documents submitted to the Commission, the Commission is not 

imposing a penalty against Fine.
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F. The Division of Enforcement (“Division”) may, at any time following the entry of 

this Order, petition the Commission to: (1) reopen this matter to consider whether Fine provided 

accurate and complete financial information at the time such representations were made; and (2) 

seek an order directing payment of disgorgement and pre-judgment interest. No other issue shall 

be considered in connection with this petition other than whether the financial information 

provided by Fine was fraudulent, misleading, inaccurate, or incomplete in any material respect. 

Fine may not, by way of defense to any such petition: (1) contest the findings in this Order; (2) 

assert that payment of disgorgement and interest should not be ordered; (3) contest the amount of 

disgorgement and interest to be ordered; or (4) assert any defense to liability or remedy, 

including, but not limited to, any statute of limitations defense. 

Payment must be made in one of the following ways: 

(1) Respondent may transmit payment electronically to the Commission, which 

will provide detailed ACH transfer/Fedwire instructions upon request; 

(2) Respondent may make direct payment from a bank account via Pay.gov 

through the SEC website at http://www.sec.gov/about/offices/ofm.htm; or 

(3) Respondent may pay by certified check, bank cashier’s check, or United 

States postal money order, made payable to the Securities and Exchange 

Commission and hand-delivered or mailed to: 

Enterprise Services Center

Accounts Receivable Branch

HQ Bldg., Room 181, AMZ-341

6500 South MacArthur Boulevard

Oklahoma City, OK 73169

Payments by check or money order must be accompanied by a cover letter 

identifying Raymond Allan Fine as a respondent in these proceedings, and the file 

number of these proceedings; a copy of the cover letter and check or money order 

must be sent to Anita Bandy, Associate Director, Division of Enforcement, 

Securities and Exchange Commission, 100 F St., NE, Washington, DC 20549. 
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V.

It is further Ordered that, solely for purposes of exceptions to discharge set forth in Section 

523 of the Bankruptcy Code, 11 U.S.C. § 523, the findings in this Order are true and admitted by 

Respondent, and further, any debt for disgorgement, prejudgment interest, civil penalty or other 

amounts due by Respondent under this Order or any other judgment, order, consent order, decree 

or settlement agreement entered in connection with this proceeding, is a debt for the violation by 

Respondent of the federal securities laws or any regulation or order issued under such laws, as set 

forth in Section 523(a)(19) of the Bankruptcy Code, 11 U.S.C. §523(a)(19).

By the Commission.

Vanessa A. Countryman

Secretary