UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES ACT OF 1933

Release No. 9931 / September 28, 2015

SECURITIES EXCHANGE ACT OF 1934

Release No. 75998 / September 28, 2015

ACCOUNTING AND AUDITING ENFORCEMENT

Release No. 3707 / September 28, 2015

ADMINISTRATIVE PROCEEDING

File No. 3-16838

In the Matter of

William C. Enloe,

Respondent.

ORDER INSTITUTING CEASE-ANDDESIST PROCEEDINGS PURSUANT TO 

SECTION 8A OF THE SECURITIES ACT 

OF 1933 AND SECTION 21C OF THE 

SECURITIES EXCHANGE ACT OF 1934, 

MAKING FINDINGS, AND IMPOSING A 

CEASE-AND-DESIST ORDER AND 

PENALTIES

I.

The Securities and Exchange Commission (“Commission”) deems it appropriate that ceaseand-desist proceedings be, and hereby are, instituted pursuant to Section 8A of the Securities Act 

of 1933 (“Securities Act”) and Section 21C of the Securities Exchange Act of 1934 (“Exchange 

Act”), against William C. Enloe (“Respondent”). 

II.

In anticipation of the institution of these proceedings, Respondent 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 in Section V herein, Respondent consents

to the entry of this Order Instituting Cease-and-Desist Proceedings Pursuant to Section 8A of the 

Securities Act of 1933 and Section 21C of the Securities Exchange Act of 1934, Making Findings, 

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

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

Summary

This proceeding resulted from the failure of Trinity Capital Corporation and its whollyowned subsidiary, Los Alamos National Bank (collectively, “Trinity” or “the Bank”), to account 

properly for the Bank’s loan portfolio during 2010, 2011 and the first two quarters of 2012 (the 

“Relevant Periods”), and to account properly for its real estate held as a result of foreclosures 

(referred to as “other real estate owned” or “OREO”) in 2011. 

By 2009, as the New Mexico economy declined during the financial crisis, the Bank 

experienced an increase in delinquent and problem loans and a decrease in the collateral values 

supporting its loan and OREO portfolio, requiring the Bank to record loan and OREO losses. 

Enloe and other former members of Trinity’s management caused the Bank to engage in false and 

misleading accounting and reporting that concealed the Bank’s loan delinquencies and declining 

collateral values and to hide the true value of its loan and OREO portfolio. This conduct resulted 

in the Bank materially misstating its provision for loan losses on its income statement and its 

allowance for loan and lease losses (“ALLL”) on its balance sheet during the Relevant Periods, 

including in its quarterly and annual filings with the Commission during 2010, 2011, and the first 

two quarters of 2012, and understating its OREO losses in 2011. This conduct by Enloe and other 

former members of the Bank’s management was aided by the Bank’s deficient internal accounting 

controls over loan and OREO accounting, as well as the overriding of internal accounting controls 

by Enloe and other employees and former members of management.

 While serving as the CEO of the Bank, Enloe facilitated the false and misleading 

accounting by pressuring loan officers to engage in improper conduct that kept the Bank from 

properly recording losses on its financial statements. Specifically, Enloe instructed and 

encouraged loan officers and others: (1) not to downgrade loans that were delinquent; (2) to make 

delinquent loans appear to be paying on time; (3) not to identify loans for which the Bank was not 

going to be paid in full; and (4) not to accurately value the Bank’s collateral. In addition, Enloe 

circumvented the Bank’s internal controls by, among other things: (a) permitting the extension of 

additional credit to delinquent borrowers without the appropriate financial analysis or supervisory 

approval; (b) improperly rejecting appraisals that evidenced declining values for real estate that 

collateralized loans; and (c) continuing to act as a loan officer when he had no lending authority. 

The fraudulent conduct was also aided by Enloe’s failure to implement sufficient internal controls 

over financial reporting at the Bank.

Respondent

1. William C. Enloe is a 66-year-old resident of Los Alamos, New Mexico. Enloe 

worked at the Bank from 1971 until his employment concluded on February 1, 2013. From 1979 

 

1 The findings herein are made pursuant to Respondent’s Offer of Settlement and are not binding on any 

other person or entity in this or any other proceeding.
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until 1994 he was the President of Trinity, and from 1994 to February 1, 2013, Enloe served as 

Trinity’s CEO. Enloe is now employed by a private company. 

Related Entity

2. Trinity Capital Corporation is a New Mexico corporation headquartered in Los 

Alamos, New Mexico. Trinity is the holding company of Los Alamos National Bank, a national 

banking organization with $1.4 billion in assets. Trinity’s common stock is registered with the 

Commission pursuant to Section 12(g) of the Exchange Act; however, its stock is not listed on any 

automated quotation system or securities exchange and no firm makes a market in its stock. In 

2010, Trinity issued common stock under a registration statement filed on Form S-8 (Registration 

No. 333-126980, filed July 28, 2005). In 2012, Trinity awarded Restricted Stock Units to certain 

personnel under the same registration statement. The registration statement incorporated by 

reference subsequent filings, including Trinity’s 2010 Forms 10-Q and 10-K, 2011 Forms 10-Q 

and 10-K, and 2012 Forms 10-Q. 

Facts

3. During 2010, 2011, and the first two quarters of 2012 (the “Relevant Periods”), 

Trinity failed to properly account for the Bank’s loan portfolio and OREO. As a result, the Bank 

filed inaccurate periodic reports with the Commission in 2010, 2011, and the first two quarters of 

2012.

4. On December 12, 2014, Trinity filed its Form 10-K for the year ended December 

31, 2013, which included the restatement of Trinity’s consolidated financial data for the year ended 

December 31, 2011 and the quarterly periods ended March 31, 2012 and June 30, 2012, and the 

restated, unaudited, selected consolidated financial data for the year ended December 31, 2010. 

According to its restatement, Trinity’s provision for loan losses was understated by $6.8 million 

(25%) in 2010, $22.3 million (73%) in 2011, and $4.5 million (68%) in the first quarter of 2012. 

Trinity overstated its provision for loan losses for the second quarter of 2012 by $2.3 million 

(31%). Additionally, in 2011, Trinity’s OREO losses were understated by $364,000 (10%). The 

restatement noted that these failures were caused in part by the override of controls by certain 

former members of management because of Trinity’s insufficient internal accounting controls, 

including controls in the loan department, internal audit, and loan accounting. The restatement 

also identified material weaknesses in Trinity’s internal controls over financial reporting.

5. During the time period at issue, the Bank’s loan policies required that loans be 

assigned one of seven descending grades based on the decreasing likelihood that the loan principal 

and interest would be collected. As discussed herein, the Bank was thereafter required under 

relevant accounting principles to recognize and/or reserve against likely loan losses. Enloe, 

directly and through instructions to lower-level employees, caused the Bank to materially misstate 

its ALLL and loan loss provision by: (1) pressuring loan officers not to downgrade troubled loans; 

(2) instructing and encouraging loan officers and others to modify loan terms and extend additional 

credit to delinquent borrowers to make unpaid loans falsely appear to be current; (3) failing to 

identify loans that were not going to be paid in full – including loans where the Bank granted 

concessions to the borrowers through restructured terms, known as troubled debt restructurings 
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(“TDRs”); and (4) failing to utilize accurate collateral valuations on impaired loans. In 2011, the 

Bank and Enloe failed properly to value and account for impairments to its OREO by not using 

appraisals that indicated that the value of OREO properties had decreased and that OREO writedowns were required. 

Failure To Downgrade Loans

6. During the Relevant Periods, the Bank’s loan department operated under a culture

that discouraged downgrading loans to special mention or substandard since the downgrading 

would lead to the recording of additional losses. Loans were to be graded special mention when 

they had potential weaknesses that deserved management’s close attention. Loans were to be 

graded substandard when they demonstrated a well-defined weakness. Loan officers were under 

pressure from Enloe and other members of management to avoid having “bad loans” in their loan 

portfolios, including any loans that were graded below pass and loans that were more than 30 days 

past due. As a result, the Bank’s loan department ignored and hid loan weaknesses that required 

downgrades and waited as long as possible to downgrade loans below pass, which sometimes 

included waiting until the loan was at or over 90 days past due, or until the loan was selected for 

review by a third party and was therefore at risk for being identified as a grade “miss.” These 

grading errors resulted in the Bank understating its ALLL because its lower graded loans carried a 

higher historical loss rate, which would have required additional losses and increased the ALLL.

7. Enloe and the Bank’s loan department undertook steps to prevent downgrades on 

certain loan relationships, including authorizing checking account overdrafts and the extension of 

additional credit to borrowers who were unable to make their required principal and interest 

payments on their existing debt. Sometimes this additional credit would be granted using loans 

referred to as “ABC Loans,” which stood for “Additional Balance Club Loans.” The additional 

credit was used to make required payments on the existing debt, which would result in the 

borrower appearing current on loan payments when, in fact, the Bank was not actually making any 

collections from the borrower.

8. Enloe, other former members of the Bank’s management, and loan department 

employees circumvented and ignored internal accounting controls by failing to downgrade troubled 

loan relationships. For example, in one instance, Enloe extended credit to a borrower without the 

required credit analyses being completed. In another instance, a borrower’s loans were first 

downgraded from pass to substandard by the internal audit department in late March 2011, were 

then updated to pass at Enloe’s direction in early April 2011, and were then again downgraded to 

substandard in May 2011 when the borrower appeared on a list of loans to be reviewed by a third 

party.

9. In the case of one borrower and his associated entities, approximately $8.8 million 

in loans were improperly graded as pass during nearly all of the Relevant Periods. In connection 

with these loans, Enloe established a practice, followed by loan department employees, of using a 

variety of techniques to ignore and hide the borrower’s troubled financial situation, including 

granting additional credit to the borrower for the purpose of making payments on existing loans 

and modifying the loans and granting the borrower concessions without downgrading the loans or 
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evaluating them as TDRs.2 Enloe and other members of the Bank’s management did not follow up 

on certain Bank employees’ concerns regarding the manner in which the Bank was managing and 

accounting for these loans. Further, Enloe and other former members of the Bank’s management 

and loan department employees undertook efforts to prevent the OCC, the Board, and other Bank 

personnel from reviewing this borrower’s loans and discovering the troubled nature of the 

borrower.

10. In another instance, Enloe authorized numerous extensions to a borrower that 

delayed the borrower’s repayment of the loans. The borrower’s financial situation and payment 

history clearly indicated that he was struggling to make his payments in accordance with the terms 

of his notes; nonetheless, at Enloe’s direction, the loan officer continued to extend additional credit 

to make interest payments and to provide renewals and extensions to prevent the borrower from 

appearing on the Bank’s past due list. Under Enloe’s direction, this borrower’s loans were not 

handled in accordance with the Bank’s internal policies and procedures. Further, in at least one 

instance, Enloe had the loan department provide the borrower additional funds in the name of his 

entity so it would not be readily apparent that a loan payment was made through the extension of 

additional credit.

Failure To Measure Individual Loan Impairments Properly

11. The Bank also made material errors by failing to measure properly the loss for 

individually impaired loans. A loan is impaired when it is probable a creditor will be unable to 

collect all amounts due according to the contractual terms of the loan agreement. If a loan is 

individually impaired, the amount of impairment must be measured and recorded as a loss with a 

corresponding amount recorded to the ALLL. Generally Accepted Accounting Principles 

(“GAAP”) permits the impairment to be measured using the fair value of the underlying collateral 

if the loan is collateral dependent, which is the method the Bank typically utilized. GAAP requires 

that the best information available in the circumstances be used to determine fair value. 

12. Among other things, appraisals were used to value the Bank’s collateral that was 

used to measure the loss on impaired collateral-dependent loans. For purposes of measuring the 

impairment on a collateral-dependent loan, the Bank was required to consider the current condition 

of the property, which can be accomplished by using an “as-is” appraisal value.3 However, in at 

least two instances, Enloe directed the use of higher “as stabilized” or “as completed” values in 

measuring impairment losses when an as-is appraisal value should have been used. 

13. One example involved a $4.2 million loan that was substandard and impaired 

during the Relevant Periods. In 2010, at the direction of Enloe, the Bank used an as-stabilized 

appraisal based on the hypothetical value of the project assuming construction was completed and 

operating profitably. The Bank then subtracted the cost-to-complete as provided by the borrower. 

 

2

Pursuant to GAAP, a restructuring of a debt constitutes a TDR if the creditor grants a concession to the 

debtor due to the debtor's financial difficulties.

3 ASC 820-10-20 defines fair value as the price that would be received to sell an asset in an orderly 

transaction between market participants as of the measurement date. The as-is appraisal considers the 

conditions of the property as of the measurement date, while the as-completed and as-stabilized appraisals 

do not.
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In the second half of 2011, the Bank obtained updated cost estimates that, if utilized, would have 

resulted in an impairment loss of approximately $1 million; however, Enloe ignored those updated 

cost-to-complete estimates. In the second quarter of 2012, the Bank finally received an appraisal 

that included an “as-is” value, which would have required an impairment loss of approximately 

$3.7 million. Enloe “rejected” the appraisal, requested it be deleted from the Bank’s electronic 

loan file, and the Bank continued to use the 2010 as-stabilized appraisal less the outdated cost to 

complete numbers. The resulting improper valuations on this loan resulted in the Bank avoiding 

approximately $3.7 million in impairment losses throughout 2011 and in the first two quarters of 

2012. 

14. In another instance, the Bank ignored an appraisal valuing the collateral supporting 

an $8.9 million loan that was substandard and impaired. Throughout 2011 and the first two 

quarters of 2012, the Bank measured the loan’s impairment by relying on a February 2011 

appraisal that valued the property at approximately $15.9 million. In March 2012, the Bank was 

notified that the property had been appraised in January 2012 in connection with foreclosure 

litigation. Using the January 2012 appraisal would have resulted in an impairment loss of 

approximately $3 million. At Enloe’s direction, the Bank disregarded the January 2012 appraisal, 

ordered another appraisal from a different appraiser, and continued to solely rely on the outdated 

February 2011 appraisal in accounting for the loan for the year-end 2011 and in the first two 

quarters of 2012, thereby avoiding recognizing loan losses totaling approximately $3 million. 

15. In another example, the Bank participated in a $20.5 million loan that was 

substandard and impaired throughout the Relevant Periods. In calculating the impairment 

throughout the Relevant Periods, Enloe directed that the Bank use the “as-stabilized” value of $32 

million from a January 2010 appraisal and $27.4 million from a January 2011 appraisal. These 

“as-stabilized” values significantly overstated the fair value of the collateral, however, because 

they assumed significant changes to the property’s operations, none of which occurred during the 

Relevant Periods. 

16. In connection with that same loan, Enloe ignored other material information 

relevant to the property’s value that indicated that the loan required a significant impairment loss, 

including a listing agreement that listed the property for sale at a price that was millions of dollars 

below the appraised “as-stabilized” values. Enloe also responded to inquiries of multiple potential 

buyers that the Bank was willing to accept a sales price that was millions of dollars below the 

appraised “as-stabilized” values. In addition, Enloe knew that another bank with an interest in the 

loan was accounting for the loan based on a collateral value of $13 million, and that an internal 

Bank analysis showed that the property could be worth $14 to $15 million assuming some 

improvements to the property’s operating condition. By failing to measure the impairment on this 

loan properly, Enloe caused the Bank to avoid recording approximately $8.9 million of loan losses 

throughout the Relevant Periods. 

17. Similarly, on another loan for $2.7 million, the Bank avoided a $1.1 million 

impairment loss in 2011 by ignoring clear evidence of a lower collateral value. In February 2012, 

the Bank consented to a letter of intent for the sale of a loan’s collateral so long as the Bank 

obtained $1.65 million from the sale. In accounting for the loan in the first quarter of 2012, 
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however, at Enloe’s direction, the Bank ignored the letter of intent and instead used the outstanding 

loan balance of $2.7 million as the collateral value.

18. Enloe also avoided necessary write downs on OREO properties by interfering with 

Trinity’s appraisal process and obtaining appraisals late. For example, in early 2011, the Bank was 

in the process of foreclosing on a facility that was held as collateral on a loan. The facility had 

appraised for $1 million in February 2010, but in March 2011 the bank received a new appraisal 

that valued the property at $550,000. Enloe directed the loan department not to use the March 

2011 appraisal and to hire a different appraiser to conduct another appraisal. On June 22, 2011, the 

Bank received a new appraisal, which valued the property at $382,000. Upon receiving an 

appraisal with an even lower value, Enloe instructed the loan department to use the March 2011 

appraisal with the value of $550,000. As a result of this conduct, the Bank improperly failed to 

recognize approximately $444,000 of impairment losses as of March 30, 2011.

Circumventing and Failing to Implement Internal Accounting Controls

19. The material misstatements and the conduct by certain former members of Bank 

management, including Enloe, were facilitated by the intentional circumvention of internal 

accounting controls, but were also aided by Enloe’s failure to devise and maintain a system of 

internal accounting controls. 

20. During the Relevant Periods, Enloe failed to implement sufficient internal 

accounting controls over the periodic review of loans to ensure loans were accurately graded and to 

identify troubled and impaired loans. Further, due to Enloe’s influence, the Bank’s internal audit 

department was not independent from management and, as a result, the Bank’s Audit Committee 

was not always provided with complete and independent internal audit findings. The Bank’s 

internal audit department also lacked a formalized risk assessment process and, as a result, did not 

sufficiently consider risks in financial reporting in establishing audit procedures. 

21. Enloe also circumvented the Bank’s processes and internal accounting controls over 

TDRs, impaired loan loss calculations, and appraisals. As noted above, Enloe was involved in 

loans that relied upon stale appraisals and collateral values improperly based on “as-stabilized” 

valuations. Enloe also ignored appraisals that came in with valuations that would result in charge 

offs. By circumventing the Bank’s processes and controls in these ways, Enloe caused the Bank to 

materially misstate its ALLL and loan loss provision.

22. Enloe also failed to implement sufficient internal controls over the accounting for

ABC Loans and the analysis of TDRs. For example, the Bank’s internal loan approval and credit 

review processes failed to require an analysis of whether a loan modification or extension was a 

TDR. Similarly, in some instances, feedback and working papers from independent, third-party 

loan reviews indicated that a TDR analysis should be performed on specific loans; however, there 

were no controls in place to confirm that this feedback was reviewed, noted, and acted upon. 

Further, during the Relevant Periods, TDRs were rarely discussed within the loan department, and 

employees were not properly instructed as to how and when to analyze modifications as potential 

TDRs. Finally, numerous loans should have been evaluated as TDRs because a new loan was 
8

provided to pay interest or principal due on an existing loan. Enloe and the Bank’s loan policy 

failed to consider whether this situation resulted in a “concession.” 

23. Enloe failed to devise and maintain internal accounting controls sufficient to 

provide reasonable assurances that the Bank’s accounting for impaired loans was in conformity 

with GAAP. Loan department personnel calculating the impaired loan losses did not possess 

sufficient accounting expertise and there was not adequate involvement or review by the

accounting department. As a result, errors occurred in the calculation of impaired loan losses. 

24. Enloe also failed to implement sufficient internal controls over appraisals. While 

the appraisal process was to be separate and independent from the loan department, in practice, 

loan department employees were charged with determining when appraisals would be ordered on 

classified loans. Further, at the direction of certain former members of the Bank’s management 

and loan department, including Enloe, appraisals were sometimes not ordered timely, delayed, or 

ordered without the standard request for an “as-is” fair value. The accounting department was not 

automatically notified when appraisals were received, which meant that it was not always aware of 

appraisals relevant to impairment measurements. 

25. Additionally, appraisals and other information were not always used, as required by 

GAAP, in the Bank’s loan impairment accounting. Enloe was aware of this by at least 2009 when 

the Bank’s outside auditor found a $2.2 million accounting error. Nonetheless, Enloe failed to 

implement controls to adequately address this issue and, throughout the Relevant Periods, the 

Bank’s internal audit and accounting departments continued to stumble across appraisals that had 

not been considered in the Bank’s accounting.

26. Enloe also failed to implement sufficient internal accounting controls over the 

Bank’s processes and computerized systems that housed appraisals and loan information. Controls 

were inadequate to ensure all received appraisals were preserved in the Bank’s database.

Numerous employees, including loan officers, had edit rights to these systems allowing them to 

alter or delete data about loans, appraisals, collateral values and customers. Because of these 

inadequacies, employees could delete appraisals or change collateral values without documenting 

why the alterations were made. When appraisals and collateral values were deleted, the result was 

that information was not made available to the OCC and other third parties, as well as other Bank 

employees.

Misleading Statements to Accountants

27. Enloe also made, or caused to be made, misleading statements to the Bank’s 

accountants. For example, Enloe was aware of false and misleading information in impairment 

memos that were provided to internal accountants and the external auditors, including incorrect 

impairment calculations on loans that understated losses. Enloe was also aware of material 

information regarding the Bank’s loan portfolio that was not provided to the external auditors, 

including evidence of significant borrower relationships where the borrowers were delinquent or 

had indicated an inability to pay and yet the Bank did not downgrade the loans below pass or 

designate the loans as impaired. 
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False Certifications

28. As CEO, during all Relevant Periods, Enloe signed certifications pursuant to 

Sections 302 and 906 of SOX in which he certified, among other things, that: (1) the information 

contained in the reports fairly presented, in all material respects, the financial condition and results 

of Trinity; (2) the financial statements were free of material misstatements and omissions; (3) he 

had disclosed any fraud involving management or other employees who had a significant role in 

the company’s internal control over financial reporting; and (4) he had designed, or caused to be 

designed, internal controls over financial reporting to provide reasonable assurance regarding the 

reliability of financial reporting and the preparation of financial statements for external purposes in 

accordance with GAAP. Nevertheless, during all Relevant Periods, Enloe knew about: (i) false 

and misleading information in impairment memos that made the information presented in Trinity’s 

quarterly and annual reports not fairly present the Bank’s financial condition and results; (ii) 

material misstatements and omissions in the Bank’s financial statements tied to the Bank’s loan 

portfolio; (iii) Trinity’s failure to follow GAAP and its own loan policy in grading loans, 

designating loans as impaired, and designating loans as TDRs; and (iv) insufficient internal 

accounting controls over properly measuring impaired loans, use of ABC loans, appraisals, and the 

Bank’s processes and computerized systems that housed appraisals and loan information.

Enloe Controlled and Directed Trinity’s Violations

29. Enloe, as the CEO of Trinity, had management authority over Trinity, and did in fact 

control and direct Trinity’s loan and OREO accounting. Further, as set forth above, Enloe orchestrated 

and was directly involved in Trinity’s fraudulent financial reporting. 

Violations

30. As a result of the conduct described above, Enloe violated Section 10(b) of the 

Exchange Act and Rule 10b-5 thereunder, which prohibit fraudulent conduct in connection with 

the purchase or sale of securities.

31. As a result of the conduct described above, Enloe violated Sections 17(a)(1) and (3)

of the Securities Act, which prohibit fraudulent conduct in connection with the offer or sale of 

securities.

32. As a result of the conduct described above, Enloe violated Section 13(b)(5) of the 

Exchange Act and Rule 13b2-1 thereunder, which prohibit persons from knowingly circumventing 

or knowingly failing to implement a system of internal accounting controls, or knowingly 

falsifying any book, record, or account.

33. As a result of the conduct described above, Enloe violated Rule 13b2-2 of the 

Exchange Act, which prohibits any officer from either (1) making or causing to be made a 

materially false or misleading statement to an accountant, or (2) omitting to state, or causing 

another person to omit to state, any material fact necessary in order to make statements made, in 

light of the circumstances under which such statements were made, not misleading, to an 

accountant, in connection with any audit, review, or examination of the financial statements of 

an issuer.
10

34. As a result of the certifications described above, Enloe violated Rule 13a-14 of the 

Exchange Act, which requires that each report filed on Forms 10-Q and10-K include 

certifications signed by the principal executive and principal financial officer of the issuer.

35. As a result of the conduct described above, Enloe caused Trinity’s violation of

Section 10(b) of the Exchange Act and Rule 10b-5 thereunder, which prohibit fraudulent conduct 

in connection with the purchase or sale of securities.

36. As a result of the conduct described above, Enloe caused Trinity’s violations of 

Section 17(a) of the Securities Act, which prohibits fraudulent conduct in connection with the offer 

or sale of securities.

37. As a result of the conduct described above, Enloe caused Trinity’s violations of 

Section 13(a) of the Exchange Act and Rules 12b-20, 13a-1, and 13a-13 thereunder, which require 

every issuer of a security registered pursuant to Section 12 of the Exchange Act to file with the 

Commission information, documents, and annual and quarterly reports as the Commission may 

require, and mandate that periodic reports contain such further material information as may be 

necessary to make the required statements not misleading.

38. As a result of the conduct described above, Enloe caused Trinity’s violations of

Section 13(b)(2)(A) of the Exchange Act, which requires reporting companies to make and keep 

books, records, and accounts, which in reasonable detail, accurately reflect their transactions and 

dispositions of their assets.

39. As a result of the conduct described above, Enloe caused Trinity’s violations of

Section 13(b)(2)(B) of the Exchange Act, which require all reporting companies to devise and 

maintain a system of internal accounting controls sufficient to provide reasonable assurances that 

transactions are recorded as necessary to permit preparation of financial statements in accordance 

with generally accepted accounting principles; and prohibit persons from knowingly circumventing 

or knowingly failing to implement a system of internal accounting controls, knowingly falsifying 

any book, record, or account, and directly or indirectly falsifying or causing to be falsified any 

book, record, or account.

IV.

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

agreed to in Respondent’s Offer.

Accordingly, it is hereby ORDERED that:

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

Respondent Enloe cease and desist from committing or causing any violations and any future 

violations of Section 17(a) of the Securities Act and Sections 10(b), 13(a), 13(b)(2)(A),

13(b)(2)(B), and 13(b)(5) of the Exchange Act and Rules 10b-5, 12b-20, 13a-1, 13a-13, 13a-14,

13b2-1, and 13b2-2 thereunder. 
11

B. Pursuant to Section 8A(f) of the Securities Act and Section 21C(f) of the Exchange 

Act, Respondent Enloe is prohibited for a period of 5 years from acting as an officer or director of 

an issuer that has a class of securities registered pursuant to Section 12 of the Exchange Act or that 

is required to file reports pursuant to Section 15(d) of the Exchange Act.

C. Respondent shall, within 20 days of the entry of this Order, pay a civil money 

penalty in the amount of $250,000.00 to the Securities and Exchange Commission. The 

Commission may distribute civil money penalties collected in this proceeding if, in its discretion, 

the Commission orders the establishment of a Fair Fund pursuant to 15 U.S.C. § 7246, Section 

308(a) of the Sarbanes-Oxley Act of 2002, as amended. The Commission will hold funds paid 

pursuant to this paragraph in an account at the United States Treasury pending a decision whether 

the Commission, in its discretion, will seek to distribute funds or, subject to Exchange Act Section 

21F(g)(3), transfer them to the general fund of the United States Treasury. If payment is not made

by the date required by this Order, the balance of the civil penalty, plus any additional interest 

accrued pursuant to 31 U.S.C. 3717, shall be due and payable immediately, at the discretion of the 

Commission staff, without further application. 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 

William C. Enloe 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 Tom Krysa, Division of 

Enforcement, Securities and Exchange Commission, 1961 Stout Street, Suite 1700, Denver, 

CO 80294-1961. 

D. Regardless of whether any such Fair Fund distribution is made, amounts ordered 

to be paid as civil money penalties pursuant to this Order shall be treated as penalties paid to the 

government for all purposes, including all tax purposes. To preserve the deterrent effect of the 

civil penalty, Respondent agrees that in any Related Investor Action, he shall not argue that he is 

entitled to, nor shall he benefit by, offset or reduction of any award of compensatory damages by 

the amount of any part of Respondent’s payment of a civil penalty in this action ("Penalty 
12

Offset"). If the court in any Related Investor Action grants such a Penalty Offset, Respondent 

agrees that he shall, within 30 days after entry of a final order granting the Penalty Offset, notify 

the Commission's counsel in this action and pay the amount of the Penalty Offset to the 

Securities and Exchange Commission. Such a payment shall not be deemed an additional civil 

penalty and shall not be deemed to change the amount of the civil penalty imposed in this 

proceeding. For purposes of this paragraph, a "Related Investor Action" means a private 

damages action brought against Respondent by or on behalf of one or more investors based on 

substantially the same facts as alleged in the Order instituted by the Commission in this 

proceeding.

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.

Brent J. Fields

Secretary