UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934 

Release No. 93980 / January 13, 2022

ADMINISTRATIVE PROCEEDING

File No. 3-16877

In the Matter of

HOWARD RICHARDS,

Respondent.

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ORDER APPROVING PLAN OF 

DISTRIBUTION

ADMINISTRATIVE PROCEEDING

File No. 3-16878

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 :

In the Matter of :

 :

JAMES GOODLAND AND SECURUS :

WEALTH MANAGEMENT, LLC, :

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Respondents. :

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On September 30, 2015, the Commission issued an Order Instituting Administrative and 

Cease-and-Desist Proceedings, Pursuant to Sections 15(b)2 and 21C of the Securities Exchange 

Act of 1934, Sections 203(f) and 203(k) of the Investment Advisers Act of 1940, and Section 

9(b) of the Investment Company Act of 1940, Making Findings, and Imposing Remedial 

Sanctions and a Cease-and-Desist Order (the “Order”)1against Howard Richards (“Richards”). 

In the Order, the Commission found that from January 2010 through July 2013, Richards, an

investment advisory representative associated with Securus Wealth Management, LLC 

(“Securus”), engaged in a manipulative scheme to support the market price of the common stock 

of Gatekeeper USA, Inc. (“Gatekeeper”) in order to help Gatekeeper to obtain financing. The 

Commission also found that Richards failed to disclose to his clients his significant conflict of 

interest arising from his ownership of Gatekeeper shares, in breach of his fiduciary duty as an 

investment adviser. The Commission ordered Richards to pay a total of $144,000 in 

disgorgement, prejudgment interest, and a civil money penalty over the period of one year. The 

 

1 Exchange Act Rel. No. 76058 (Sept. 30, 2015).
2

Commission also created a Fair Fund, pursuant to Section 308(a) of the Sarbanes-Oxley Act of 

2002, for the monies received pursuant to the Order.

In a related action, also on September 30, 2015, the Commission issued an Order 

Instituting Administrative and Cease-and-Desist Proceedings, Pursuant to Sections 203(e), 203(f) 

and 203(k) of the Investment Advisers Act of 1940, Making Findings, and Imposing Remedial 

Sanctions and a Cease-and-Desist Order (the “Company Order”)2against James Goodland 

(“Goodland”) and Securus. In the Company Order, the Commission found that, from January 

2010 through July 2013, Securus, an investment adviser registered with the Commission, and 

Goodland, its President and Chief Compliance Officer, failed to reasonably supervise Richards. 

Securus and Goodland also failed to adopt and implement an adequate system of internal 

controls that would have prevented and detected violations of the Investment Advisers Act of 

1940. In the Company Order, the Commission ordered Goodland to pay a $30,000 civil money 

penalty. The Commission also created a Fair Fund, pursuant to Section 308(a) of the SarbanesOxley Act of 2002, so the penalty could be distributed to harmed investors. The Company Order 

also provided that the funds could be distributed by the Fair Fund established in the Order. 

The Fair Fund includes the $174,000.00 paid by the Respondents.

The assets of the Fair Fund are subject to the continuing jurisdiction and control of the 

Commission. The Fair Fund has been deposited in an interest-bearing account at the U.S. 

Department of the Treasury’s Bureau of the Fiscal Service, and any interest accrued will be 

added to the Fair Fund.

On November 23, 2021, the Division of Enforcement, pursuant to delegated authority, 

published a Notice of Proposed Plan of Distribution and Opportunity for Comment (“Notice”),3

pursuant to Rule 1103 of the Commission’s Rules on Fair Fund and Disgorgement Plans 

(“Commission’s Rules”);4and simultaneously posted the Proposed Plan of Distribution (the 

“Proposed Plan”). The Notice advised interested persons that they could obtain a copy of the 

Proposed Plan from the Commission’s public website or by submitting a written request to Amy 

Sumner, United States Securities and Exchange Commission, 1961 Stout Street, Suite 1700, 

Denver, CO 80294. The Notice also advised that all persons desiring to comment on the 

Proposed Plan could submit their comments, in writing, within 30 days of the Notice. The 

Commission received no comments on the Proposed Plan during the comment period. 

The Proposed Plan provides for the distribution of the Net Available Fair Fund5to 

investors who paid management fees on and/or suffered a loss on transactions in eligible 

securities during the relevant period as calculated by the methodology used in the plan of 

allocation in the Plan. 

 

2 Advisers Act Rel. No. 4213 (Sept. 30, 2015).

3

 Exchange Act Rel. No. 93664 (Nov. 23, 2021).

4

 17 C.F.R. § 201.1103.

5

 All capitalized terms used herein but not defined shall have the same meanings ascribed to them in the Proposed 

Plan.
3

The Division of Enforcement now requests that the Commission approve the Proposed 

Plan. 

Accordingly, it is hereby ORDERED, pursuant to Rule 1104 of the Commission’s Rules,6

that the Proposed Plan is approved, and the approved Plan of Distribution shall be posted 

simultaneously with this order on the Commission’s website at www.sec.gov.

For the Commission, by the Division of Enforcement, pursuant to delegated authority.7

Vanessa A. Countryman

Secretary 

 

6

 17 C.F.R. § 201.1104. 

7

 17 C.F.R. § 200.30-4(a)(21)(iv).