The complaint said that $3 million went to credit cards, while $1.5 million was withdrawn in cash, $1.3 million went to Mister Farms, $300,000 went to pay for a leased residence in Manhattan and $248,000 went to a second residence in Santa Fe for both a down payment and mortgage payments. The SEC said Ruiz used $157,000 for school loan repayments.

“Ruiz,” the SEC complaint says, “also used new investor funds he raised for RAM to make approximately $1.4 million in Ponzi-like payments to some of the existing investors, thus creating the illusion that RAM was a profitable enterprise, though its bank accounts show no income from real estate, lending activity, or otherwise.”

According to Carter Bain’s website, the firm is based in Deming and Las Cruces, N.M.

The Department of Homeland Security was also involved in the investigation.

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