The Commission’s civil complaint, filed in federal district court in Dallas, alleges that between 2005 and 2009 Froning solicited fifteen individuals through an unregistered offering of promissory notes secured by rights to convert to equity interests in a now defunct financial planning company Froning owned. While Froning represented to investors that offering proceeds would be used to fund operating expenses and growth of the financial planning company, he diverted the proceeds to a personal bank account and used them to pay for personal expenses such as cash withdrawals, purchases from internet retailers, adult entertainment, meals, and groceries. He also used investor funds to make Ponzi payments to some investors..

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