1 

SUPPLEMENTAL DECLARATION OF MELISSA DAVIS 

Pursuant to 28 U.S.C. Section 1746, the undersigned states as follows: 

1. My name is Melissa Davis. I am over twenty-one years of age and have 

personal knowledge of the matters set forth herein. 

2. I am Partner at KapilaMukamal, LLP (“KM”), a forensic and insolvency 

advisory CPA firm. I am a Certified Public Accountant, Certified Insolvency Restructuring 

Advisor and a Certified Fraud Examiner and a practitioner addressing forensic accounting 

issues for more than 15 years. KM was retained by the Securities and Exchange 

Commission to analyze the baking activity of Complete Business Solutions Group, Inc. 

d/b/a Par Funding (“Par Funding”). 

3. On July 23, 2020 I issued a Declaration summarizing certain transfers and 

activity based on my analysis of the Par Funding bank records (“July 23, 2020 

Declaration”). A copy of the July 23, 2020 Declaration is attached as Exhibit A. The 

information in this Declaration is based on my review and analysis of the documents 

identified in the July 23, 2020 Declaration.1 

4. In addition to the activity I identified in the July 23, 2020 Declaration, I 

determined that from July 2015 to June 2020, Par Funding transferred $42,334,600 to 

Heritage Business Consulting and transferred $42,643,174 to Eagle Six Consulting, Inc. 

from Par Funding Accounts containing commingled Investor Funds.

5. During the period July 2015 to June 2020, Par Funding transferred 

$1,097,725 to Broadway Advance, LLC from Par Funding Accounts containing 

commingled Investor Funds. 

6. Beginning in December 2019 through February 21, 2020, Par Funding 

made a series of transfers to Priority Payment Systems totaling $63,650,827 from the Par 

Funding Accounts containing commingled Investor Funds. 

7. On February 21, 2020 Par Funding began to make transfers out of the Par 

Funding Accounts which were labeled as “Par Funding Pref.” During the period from 

February 21, 2020 to June 30, 2020, these transfers totaled $45,990,953, of which 

$20,865,953 occurred during the month of June 2020 from the JP Morgan Chase 

accounts. Based on my discussions with the SEC, although labeled as Par Funding Pref, 

these transfers were also payments to Priority Payment Systems from the Par Funding 

Accounts. 

1 In addition to the documents identified in Exhibit A, I also reviewed the June 2020 bank statements for 

Par Funding Glacier bank accounts to determine the inflows, outflows and ending balance. I also 

reviewed correspondence from JP Morgan and Glacier bank regarding the Par Funding bank account 

balances in July 2020.

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8. Table 1 summarizes the beginning balances, inflows, outflows and ending 

balances in the Par Funding Accounts for 2020: 

9. Table 2 summarizes the ending bank account balances in the Par Funding

Accounts by bank for each month in 2020. The ending balances in July 2020 were less 

than the ending balances as compared to prior months in 2020. 

10. On July 7, 2020 Par Funding closed the JP Morgan Chase account numbers 

ending in 9118 and 9126. On July 20, 2020 Par Funding closed the JP Morgan Chase 

bank account ending in 9100.2 

2 Based on correspondence dated July 31, 2020 from JP Morgan Chase. The balances in the JP Morgan 

accounts at the time they were closed was $323,115 and this amount is not included within the totals in 

Table 2. Only the Glacier accounts remained opened as of July 31, 2020.

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1 

DECLARATION OF MELISSA DAVIS 

Pursuant to 28 U.S.C. Section 1746, the undersigned states as follows: 

1. My name is Melissa Davis. I am over twenty-one years of age and have 

personal knowledge of the matters set forth herein. 

2. I am Partner at KapilaMukamal, LLP (“KM”), a forensic and insolvency 

advisory CPA firm. I am a Certified Public Accountant, Certified Insolvency Restructuring 

Advisor and a Certified Fraud Examiner and a practitioner addressing forensic accounting 

issues for more than 15 years. 

3. KM was retained by the Securities and Exchange Commission (“the 

Commission”), which asked me to review the following financial materials for purposes of 

issuing this Declaration: 

a. Bank records, signature cards and accounting opening documents for 

Complete Business Solutions Group d/b/a Par Funding “Par Funding” 

(“Par Funding or CBSG”) bank accounts (“Par Funding Accounts”) listed 

in Table 1: 

b. Bank Records for Fidelis Financial Planning, LLC (“Fidelis”) for the 

period July 2015 to June 2020 (“Fidelis Accounts”) listed in Table 2: 

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c. Par Funding investor Promissory Notes and Security Agreements, and 

d. CamaPlan Self Directed IRA (“CamaPlan”) transaction schedules. 

4. The information contained in paragraphs 5 to 20 are based on my review 

and analysis of the documents identified in paragraph 3. 

5. The signature cards and account opening documents for the Par Funding 

bank accounts identified in Table 1 above reflect that Lisa McElhone is an authorized 

signatory on each Par Funding bank account. 

6. From July 2015 until June 2020, the Par Funding Accounts show a total of 

$119,836,389 in incoming funds from individuals or IRA self-directed accounts who have 

executed security agreements or promissory note with CBSG. 

7. From July 2015 until June 2020, the Par Funding Accounts show a total of 

$4,678,425 in incoming funds from individuals or IRA self-directed accounts or entities 

who have similar names as the investors referred to in ¶6 or, the activity appears to be 

investor activity. 

8. Collectively these incoming funds, totaling $124,514,814, are referred to in 

this Declaration as “Investor Funds”. The Investor Funds were commingled in the Par 

Funding Accounts with funds from other sources including the Par Funding business 

operations. I determined the following as it relates to the Investor Funds: 

a. $92,460,225 of these Investor Funds were received by Par Funding 

between July 2015 and December 2017. 

b. $32,054,589 of these Investor Funds were received by Par Funding 

between January 2018 and June 2020. 

c. $15,374,950 of these Investor Funds were received by Par Funding from 

CamaPlan accounts between July 2015 and June 2020. 

9. The Commission identified certain entities that are referred to as Agent 

Funds. I determined that there were incoming funds in the form of wire transfers and 

deposits to the Par Funding Accounts from the Agent Funds totaling $367,884,080 during 

the period July 2015 to June 2020 and there were incoming funds in the form of wire 

transfers and deposits to the Par Funding Accounts from the Agent Funds totaling 

$357,104,247 during the period from January 2018 to June 2020. 

10. The total incoming Investor Funds and Agent Funds Par Funding received 

during the period July 2015 to June 2020 totals $492,398,894. 

 

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11. The Par Funding bank accounts reflect the following information with 

respect to the entities wiring or otherwise sending funds to Par Funding beginning in 

January 2018: 

Table 3 

Time Period Entity Name Total Amount 

Entity Transferred 

to Par Funding 

Accounts 

February 2018 – July 2019 ABFP Income Fund1 $25,487,690 

August 2018 – November 

2019 

ABFP Income Fund 2 $13,252,600 

May 2018 – December 2019 Fidelis Financial Planning $11,603,000

April 2019 – January 2020 Retirement Evolution Group $6,500,000

June 2018 – July 2019 Retirement Evolution Income 

Fund 

$1,825,000 

12. Between July 2015 and October 2019, Par Funding transferred

approximately $11.3 million to McElhone directly from Par Funding Accounts containing 

commingled Investor Funds. 

13. Between July 2019 and October 2019, Par Funding transferred

approximately $1.8 million to ALB Management from Par Funding Accounts containing 

commingled Investor Funds. 

14. Between July 2016 and April 2019, Par Funding transferred approximately 

$4.9 million to Beta Abigail from Par Funding Accounts containing commingled Investor 

Funds. 

15. Between February 2017 and November 2019, Par Funding transferred 

approximately $9.5 million to New Field Ventures, LLC from Par Funding Accounts 

containing commingled Investor Funds. 

1 This amount includes all incoming funds with the payor description “ABFP Income Fund, LLC” in the 

transaction support. There are additional incoming funds where the transaction support payor name is 

“ABFP Income Fund”. Since there are multiple entities that begin with the name “ABFP Income Fund” I 

did not include those amounts which total $16,547,000 within Table 3. 

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16. Between July 2018 and September 2018, Par Funding transferred about 

$14.3 million to the LME 2017 Family Trust from Par Funding Accounts containing 

commingled Investor Funds. 

17. The Par Funding Accounts reflect the following information with respect to 

money Par Funding transferred to the entities set forth below: 

Table 4 

Time Period Entity Name Total Amount 

Transferred From 

Par Funding 

Accounts 

August 2016 – January 2018 Abetterfinancialplan.com $1,914,045 

February 2019 – October 2019 ABFP Income Fund $12,735,528 

February 2019 – November 2019 ABFP Income Fund 2 $6,537,788 

June 2018 – May 2020 Fidelis Financial 

Planning 

$4,675,066 

July 2018 – December 2019 Retirement Evolution 

Income Fund 

$2,099,583 

18. The Par Funding Accounts reflect that from July 2015 to June 2020 Par 

Funding paid $5,909,322 to law firms. 

19. As of May 29,2020, the balance in the Par Funding Glacier Bank account 

was $6,763,578.2 As of June 30, 2020 the balance is the Par Funding JP Morgan Chase 

accounts total $82,319 after transfers labeled “Par Fund Pref” totaling $20,865,953 were 

made out of the JP Morgan accounts during the month of June 2020. 

20. Based on my review of the Fidelis Bank Account records identified in Table 

2, I determined that Fidelis received $8,726,200 from parties who appear to be investors 

during the period April 2018 through June 2020. 

21. I reserve the opportunity to revise this Declaration based on additional 

information that may become available. 

*********** 

2

 The June 2020 bank statement for Glacier Bank account was not available as of the date of this Declaration. 

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