UNITED STATES SECURITIES AND EXCHANGE COMMISSION

The Securities and Exchange Commission ("Commission") deems it appropriate and in the public interest that public administrative proceedings be, and hereby are, instituted pursuant to Section 15(b) of the Securities Exchange Act of 1934 ("Exchange Act") against Daniel E. Levin ("Levin" or "Respondent"). The Commission finds that Levin was the founder and sole managing member of Comprehensive Retirement Planning, LLC ("CRP LLC"), a Texas limited liability company Levin formed with its principal place of business in Dallas, Texas. CRP LLC was not registered with the Commission in any capacity. Through CRP LLC, Levin formed CRP Automotive Portfolio, LP ("CRP Fund"), a Texas limited partnership with its principal place of business Dallas, Texas. Levin controls CRP Fund and CRP LLC. CRP Fund is not registered with the Commission in any capacity. Levin has not been associated with a broker or dealer since 2014. Levin was associated with broker-dealers registered with the Commission from 1984 to August, 2014. Levin previously held multiple securities licenses, including the Series 7, 63, and 65 licenses. Levin was the subject of a previous Commission action. See Milkie Fergusson Inv., Inc., Rel. No. 33-8990, (Dec. 17, 2008). On July 26, 2023, a judgment was entered by consent against Levin, permanently enjoining him from future violations of Sections 15(a)(1) of the Exchange Act, in the civil action entitled Securities and Exchange Commission v. Daniel E. Levin, Civil Action Number 3:23-CV1025, in the United States District Court for the Northern District of Texas. The Commission's complaint alleged that, among other things, from approximately April 2017 through December 2018, Levin, through CRP LLC, sold CRP Funds' securities. CRP Funds' securities offerings were not registered with the Commission. The Commission alleged that in connection with his sale of shares in CRP Fund, Levin advised investors on the merits of investments, regularly participated in securities transactions, actively participated in all aspects of investor solicitations and sales, and received transaction-based compensation.

Order

Bar (Permanent)

association with a broker, dealer, investment adviser, municipal securities dealer, municipal advisor, transfer agent, or NRSRO

Indefinite

9/11/2023

participating in any offering of a penny stock

Indefinite

9/11/2023

UNITED STATES SECURITIES AND EXCHANGE COMMISSION

The Securities and Exchange Commission (the "Commission"), for its Complaint against Levin, alleges that Levin violated the requirement that persons engaging in the business of effecting securities transactions for others be registered by soliciting over $2.6 million from at least 27 investors from 2017 through 2018, without being registered. This conduct brought Levin within the statutory definition of a broker. As a result, Levin was required to register with the Commission under Section 15(a) of the Securities Exchange Act of 1934 ("Exchange Act"). Despite not having a brokerage license, Levin solicited investors, primarily in Texas, to purchase units of the CRP Automotive Portfolio, LP (the "CRP Fund"), which Levin established through another entity he controlled, Comprehensive Retirement Planning, LLC ("CRP LLC"). The CRP Fund then invested investor funds in a separate funds controlled by a New York-based alternative asset management firm, GPB Capital, Inc. ("GPB Capital"). By virtue of the conduct alleged herein, Levin has engaged in acts, practices, transactions and courses of business that constitute violations of Section 15(a) of the Exchange Act, 15 U.S.C. § 78o(a).

Judgment Rendered

Civil and Administrative Penalty(ies)/Fine(s)

Disgorgement

$320,000.00

Monetary Penalty other than Fines

Injunction

FINRA

WITHOUT ADMITTING OR DENYING THE FINDINGS, LEVIN CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE HOSTED A WEEKLY RADIO SHOW DURING WHICH HE MADE STATEMENTS THAT WERE UNBALANCED, PROMISSORY, MISLEADING AND/OR LACKED REASONABLE BASIS. THE FINDINGS STATED THAT LEVIN UTILIZED THE SHOW TO MARKET HIS RETIREMENT PLANNING BUSINESS. DURING THE SHOWS, LEVIN REPEATEDLY TOUTED THE BENEFITS OF INVESTING IN EQUITY INDEXED ANNUITIES (EIAS), ALTHOUGH HE DID NOT MENTION THIS PRODUCT BY NAME. INSTEAD, LEVIN ONLY GENERICALLY DESCRIBED THE POSITIVE FEATURES AND CHARACTERISTICS OF THE EIAS THAT HE WAS SELLING TO HIS CUSTOMERS. LEVIN ALSO MADE UNWARRANTED PERFORMANCE PROJECTIONS WITHOUT DISCLOSING THAT THEY WERE DEPENDENT ON THE PERFORMANCE OF AN INDEX.

Acceptance, Waiver & Consent(AWC)

Civil and Administrative Penalty(ies)/Fine(s)

$25,000.00

Requalification

Suspension

ALL CAPACITIES

SIX MONTHS

8/17/2015

2/16/2016

Daniel Edward Levin was named in a customer complaint that asserted the following causes of action: breach of fiduciary duty, misrepresentations and omissions, negligence, breach of contract, and violations of California Code 25110 et seq. and 25503 and 25504.

$280,000.00

FINRA

ACTED IN CONTRAVENTION OF SECTION 5 OF THE SECURITIES ACT OF 1933, FINRA RULE 2010, NASD RULES 2110, 2210(D)(1)(A), 2210(D)(1)(B), 2210(D)(1)(D): LEVIN, A REGISTERED REPRESENTATIVE WITH HIS MEMBER FIRM, HOSTED A WEEKLY RADIO SHOW THAT AIRED ON RADIO STATIONS AND HE MADE UNWARRANTED AND MISLEADING STATEMENTS AND CLAIMS CONCERNING INVESTMENT PRODUCTS. LEVIN AND HIS FIRM MADE UNBALANCED STATEMENTS, AND UNWARRANTED STATEMENTS AND CLAIMS ON THEIR WEBSITE REGARDING LIFE SETTLEMENTS. LEVIN DISCUSSED PRIVATE PLACEMENT SECURITIES OFFERINGS AND PROMOTED THEM AS ATTRACTIVE ALTERNATIVE INVESTMENTS TO HIS LISTENERS DURING HIS RADIO SHOWS. THESE OFFERINGS WERE UNREGISTERED SECURITIES OFFERED PURSUANT TO THE EXEMPTIONS OFFERED BY RULE 506 OF REGULATION D. THESE OFFERINGS COULD NOT BE SOLD THROUGH GENERAL SOLICITATIONS AND STILL MAINTAIN THEIR EXEMPT STATUS. THE ACTIONS CONSTITUTED GENERAL SOLICITATIONS. THESE STATEMENTS WERE NOT MADE TO CUSTOMERS WITH WHOM LEVIN (OR THE ISSUER) HAD A PRE-EXISTING AND SUBSTANTIVE RELATIONSHIP, BUT RATHER BROADCAST INDISCRIMINATELY TO THE GENERAL PUBLIC. AFTER MAKING THE STATEMENTS ON THE RADIO SHOW, LEVIN SOLD THE OFFERINGS TO CUSTOMERS. THUS, LEVIN'S SALES WERE IMPERMISSIBLE SALES OF UNREGISTERED SECURITIES. LEVIN, ACTING ON BEHALF OF THE FIRM, ALSO CONTACTED THE WHOLESALER FOR ANOTHER LIFE SETTLEMENT INVESTMENT THAT THE FIRM HAD BEEN SELLING PREVIOUSLY. THE WHOLESALER RAISED IN AN EMAIL SEVERAL CONCERNS REGARDING AN OFFERING, AND LEVIN SHARED THESE CONCERNS WITH THE RESPONSIBLE PRINCIPAL, BUT THE PRINCIPAL FAILED TO RESPOND TO THEM. LEVIN ALSO RAISED THE WHOLESALER'S CONCERNS WITH THE PRESIDENT OF THE ISSUER, WHO RESPONDED BY OFFERING THE WHOLESALER A OVERRIDE COMMISSION ON ALL OF THE FIRM'S SALES OF THE OFFERING IF HE WOULD GIVE THE INVESTMENT HIS BLESSING, AND HE DECLINED TO APPROVE THE OFFERING IN EXCHANGE FOR THE OVERRIDE. AFTER CONFIRMING THAT THE OVERRIDE COMMISSION COULD INSTEAD BE PAID TO THE FIRM, IN ADDITION TO THE REGULAR COMMISSION THAT THE ISSUER WAS OFFERING, THE PRINCIPAL SIGNED THE SELLING AGREEMENT WITH THE ISSUER ON BEHALF OF THE FIRM.

Decision & Order of Offer of Settlement

Civil and Administrative Penalty(ies)/Fine(s)

$30,000.00

Suspension

ANY CAPACITY

FIVE MONTHS

6/17/2013

11/16/2013

WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEVIN CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE HE IS FINED $30,000 AND SUSPENDED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY FOR FIVE MONTHS. THE FINE IS DUE AND PAYABLE EITHER IMMEDIATELY UPON RE-ASSOCIATION WITH A MEMBER FIRM FOLLOWING THE SUSPENSION OR PRIOR TO ANY APPLICATION OR REQUEST FOR RELIEF FROM ANY STATUTORY DISQUALIFICATION RESULTING FROM THIS OR ANY OTHER EVENT OR PROCEEDING, WHICHEVER IS EARLIER. THE SUSPENSION IS IN EFFECT FROM JUNE 17, 2013, THROUGH NOVEMBER 16, 2013. FINE PAID IN FULL ON 4/3/2015.

UNITED STATES SECURITIES AND EXCHANGE COMMISSION

SEC ADMIN RELEASES 33-8990, 34-59115, DECEMBER 17, 2008: SECTION 17(A)(2) AND (3) OF THE SECURITIES ACT OF 1934 - THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT") AND SECTION 15(B)(6) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINST DANIEL EDWARD LEVIN ("LEVIN"). LEVIN OFFERED AND SOLD MUTUAL FUND CLASS "A" SHARES TO RETAIL CUSTOMERS WITHOUT ADEQUATE DISCLOSURE OF MATERIAL INFORMATION ABOUT THE AVAILABILITY OF BREAKPOINT DISCOUNTS FOR WHICH CUSTOMERS COULD HAVE QUALIFIED. LEVIN RECOMMENDED THAT HIS CUSTOMERS ALLOCATE THEIR INVESTMENTS AMONG SEVEN TO TEN DIFFERENT FUND FAMILIES. IN THOSE INSTANCES WHERE LEVIN'S RECOMMENDED ALLOCATION QUALIFIED CUSTOMERS FOR BREAKPOINT DISCOUNTS, HE SOMETIMES ADVISED THEM THAT THEY HAD RECEIVED DISCOUNTS. HOWEVER, LEVIN DID NOT ADEQUATELY DISCLOSE, BEFORE CUSTOMERS MADE INVESTMENT DECISIONS, ALL BREAKPOINT DISCOUNTS FOR WHICH THE CUSTOMERS COULD QUALIFY IN THE FUND FAMILIES HE RECOMMENDED, NOR DID HE ADEQUATELY DISCLOSE THE BREAKPOINT DISCOUNTS CUSTOMERS COULD HAVE RECEIVED BY INVESTING LARGER AMOUNTS IN FEWER FUND FAMILIES. LEVIN'S CUSTOMERS COULD HAVE QUALIFIED FOR BREAKPOINT DISCOUNTS TOTALING UP TO $79,981.74. LEVIN ALSO FAILED TO ADEQUATELY DISCLOSE THE FINANCIAL IMPACT THOSE ADDITIONAL BREAKPOINT DISCOUNTS COULD HAVE ON THE CUSTOMERS' CONTEMPLATED TRANSACTIONS, AND THAT PURCHASES BELOW THE ADDITIONAL BREAKPOINTS WOULD RESULT IN A GREATER PROFIT TO HIM. AS A RESULT, THE CUSTOMERS WERE NOT AFFORDED THE OPPORTUNITY TO EVALUATE THE DESIRABILITY OF MAKING A QUALIFYING PURCHASE TO TAKE ADVANTAGE OF ALL BREAKPOINT DISCOUNTS AVAILABLE TO THEM.

Order

Monetary/Fine

$25,000.00

Cease and Desist/Injunction

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, RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 ("ORDER"). LEVIN WILLFULLY VIOLATED SECTION 17(A)(2) AND (3) OF THE SECURITIES ACT. IT IS HEREBY ORDERED THAT: LEVIN CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 17(A)(2) AND (3) OF THE SECURITIES ACT. RESPONDENT SHALL WITHIN 10 DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY PURSUANT TO SECTION 21B OF THE EXCHANGE ACT IN THE AMOUNT OF $25,000 TO THE SECURITIES AND EXCHANGE COMMISSION. IF TIMELY PAYMENT IS NOT MADE, ADDITIONAL INTEREST SHALL ACCRUE PURSUANT TO 31 U.S.C. 3717. SUCH CIVIL MONEY PENALTY MAY BE DISTRIBUTED PURSUANT TO SECTION 308(A) OF THE SARBANES-OXLEY ACT OF 2002 ("FAIR FUND DISTRIBUTION").

RESPONDENT WITHOUT ADMITTING OR DENYING THE FINDINGS CONSENTED TO THE ENTRY OF THE ORDER.