A company posted an ad on craigslist looking for part time Administrative Assistants to work from home. We all met with Blake Kelley in person from Southwest Elite Services (SWES) in a conference room at a hotel in Scottsdale on September 10 and we were told that he owned a company that promoted services and resources for not-for profit and non-profit agencies. He claimed to have been in business for 5 years and was a family business and that they had total transparency. | The job we were being hired to do was to recruit Community Engagement Specialists, Social Media Specialists, and Financial Service Specialists, to help promote a free online 90 day program to teach people how to position themselves to be able to run their own business and non profit foundations and to receive grants and funds to do so. This was to stimulate economic growth, etc. There was to be a black tie affair that we would be given a budget for and we would need to plan for next fall to thank everyone for bringing this to fruition and to meet some of the people involved with this conglomeration of not-for profit agencies that put this program together. It was to be a 5-year program and they asked that we commit to at least 1 year, but we could sign a 5-year contract if we so desired. In addition to recruiting the above people to do their jobs, we were to plan this event and to check up on our team to make sure they were doing what they were supposed to be doing. Every single person on the team was required to have a DBA, or a trade name or LLC, etc. We were also required to have key man insurance, which struck all of us as odd. Why would 1099 people working from home part time need key man insurance? But the company was giving us a stipend to pay for it, so we kind of brushed our concerns aside. | Once we signed up, we received a task list to be completed by Oct 1. We promptly got to work, placing and paying for ads out of our own pockets as we were told that we would be reimbursed $100 for the ads for the first 3 months only. We were all divided up across the country and were told to advertise in the areas we were assigned to. Everything went along smoothly and we were all excited about being involved with promoting such a good tool for people. Each team was required to bring on board 48 people. This seemed rather unrealistic to do in less than 2 weeks, but we all put forth a tremendous effort. On September 24 during a conference call, 1 week before our first pay day, Blake informs us that because the numbers were not what they were supposed to be, we will not be getting our $1600 in addition to the $225 we were getting to cover the insurance premium and the ads. We would only be paid $33 per person that we had brought on board. People became angry and concerned as this clearly violated our contract. It was at this point that people started becoming suspicious that this was a scam somehow. People started talking to each other and comparing notes and this is what we figured out: | 50 people were hired to recruit 48 other people. This totals 2450 people. The insurance commission on selling these people policies they don’t need, but are being forced to buy in order to have a job would range from $350-$550 per policy depending on the policy and the level of the agent. Dillard Kelley is Blake Kelley’s father and he’s the one selling these policies through Primerica. Even assuming the commission amount was the low end of $350, that would 857K in commission over a period of about a month. 45 people on each of the 50 teams were going to be required to sign up 6 “students” for the online program each week in order to be paid. Since this is a 12 week program, that would be another 270 people per week signing up. Over the course of the 12 week program, that would equate to 3240 more people that would be required to buy insurance or some other financial products for another 113K in commission. Then we uncovered Blake’s SEC filing and realized that Blake was using these student to turn them into sophisticated buyers in order to sell his unregistered securities to. The form D is filed with a 506b exemption allowing Blake to sell unregistered securities as long as he sells them to “sophisticated buyers” which is why we all need to go through the Start Regal program, which is the name of this online program. By the time we were done with the program we would meet the SEC guidelines for a “sophisticated buyer”. This is also why we needed to register a business entity. Blake isn’t legally allowed to be selling insurance like he is, neither is Dillard. By soliciting for “students” and “contractors” instead of customers or business per se, Blake gets to skirt several securities laws. Insurance is a security and it is governed by the securities exchange commission. They have guidelines on fraud and Blake ticks most of the boxes. By educating the “students” Blake turns them in to “sophisticated buyers” and is then allowed to sell them securities without registering the security. We also uncovered 2 other companies associated with him that appear to be similar to SWES, and are more than likely fraudulent. Prosperity Trade Movement and Midwest Elite Services. www.indeed.com/cmp/Prosperity-Trade-Movement. He is currently advertising similar jobs through Prosperity Trade Movement throughout the country. Despite extensive internet searches, we can find nothing on Blake or SWES in terms of prior campaigns, photos of black ties events, etc, etc. However, he does have a criminal record involving theft, false report to law enforcement out of Scottsdale AZ. | www.sec.gov/answers/rule506.htm | This is why Blake is so adamant that we “don’t solicit for business or customers” that’s why we’re soliciting for “employees” or “students.” This is also how he gets around the DNC rules.


Name: Blake Kelley

Country: United States

State: Arizona

City: Scottsdale