SEC Obtains Final Consent Judgments in $1M Offering Targeting Black Community

The U.S. district courts for the Northern District of Texas and the Southern District of Texas respectively entered final consent judgments in the U.S. Security and Exchange Commission’s civil enforcement actions against Texas residents Kevin L. Jefferson and Demetrius L. Early.
Jefferson and Early – who were never registered as a broker-dealer or associating with or activing under the supervision of a registered broker-dealer – consented to the entry of the judgments without admitting or denying the SEC’s allegations and have agreed to pay a total of more than $1.1 million to settle charges that Jefferson, with Early’s assistance, raised over $1 million from more than 65 investors through a fraudulent offering of unregistered securities, targeting members of the African American community in the greater Shreveport, La., and Dallas and Houston, Texas, metropolitan areas and elsewhere.
The SEC’s complaints, filed on Sept. 29, 2025, alleged that from at least January 2023 through December 2023, Jefferson and Early, one of Jefferson’s primary sales agents, solicited investors to purchase membership interests – between $10,000 and $25,000 – in Jefferson’s Cashflow Creation Club, telling them Jefferson would make foreign currency exchange, or Forex, trades on their behalf.
Jefferson allegedly used his networking connections with local businesses, accountants, realtors, podcasters and motivational speakers, focusing primarily within the African American entrepreneurial community, first in Texas, and then expanding nationwide through word-of-mouth referral business.
Allegedly, Jefferson promoted himself as an expert Forex trader and represented to investors that they would earn 3% to 5% monthly returns of approximately $6,000 per month, and that they should expect to grow those monthly returns up to approximately $83,000 by the end of the year. The complaints alleged that instead, Jefferson used approximately $170,000 of investor funds toward purported investment-related expenses, misappropriating nearly 85% of investor funds to pay undisclosed sales commissions to Early (and others) and for his personal expenses.
According to the complaint, he solicited unsophisticated investors, including more than 10 investors older than age 65, who had little-to-no experience with Forex trading.
In addition to personally soliciting investors, Jefferson also allegedly retained sales agents who solicited investors. Jefferson and his sales agents typically solicited investors by video conference or through seminars, and after investors transmitted funds, Jefferson communicated with them by telephone, Zoom, or email.
Without admitting or denying the allegations, Jefferson and Early consented to the entry of final judgments, which permanently enjoined them from violating the registration provisions of Section 5(a) and 5(c) of the Securities Act of 1933 and Section 15(a) of the Securities Exchange Act of 1934, and enjoined Jefferson from violating the antifraud provisions of Section 17(a) of the Securities Act and Section 10(b) of the Exchange Act and Rule 10b-5 thereunder.
The final judgments also ordered Jefferson to pay $580,913 in disgorgement plus prejudgment interest of $35,490, and a $236,451 civil penalty, and ordered Early to pay $205,267 in disgorgement plus prejudgment interest of $22,529, and a $75,000 civil penalty. The final judgments additionally prohibit Jefferson and Early from participating in the issuance, purchase, offer, or sale of any securities (with the exception of trading in their personal accounts) and acting as or being associated with any broker or dealer.


