b'1.Stephens sent offering materials (including, private placement memorandums, due diligence materials and subscription documents) to potential investors;2.Stephens suggested that investors diversify their investment portfolios to accommodate an investment in Ranieri Partners; and3.Stephens provided an analysis of Ranieris fund strategy and performance track record; and4.Stephens disclosed confidential identities and capital commitments of other members.Inexchangeforhisefforts,Stephensearnedafeeof1%ofall investments he generated. Rainieri and Phillips collectively paid a $450k fine (Rainieri and Phillips were cited for failure to supervise an unlicensed broker), and Stephens was barred from the securities industry.Kim Kardashian Anti-Touting Rule Violation An even more recent example was the settlement between the SEC and Kim Kardashian in 2022. The SEC filed charges against Kim Kardashian forpromotingacrypto-currencyofferingforEMAXtokensofferedby EthereumMax on her Instagram account, but failing to disclose the $250k payment she received for doing it.GurbirS.Grewal,DirectoroftheSECsDivisionofEnforcement stated, The federal securities laws are clear that any celebrity or other individual who promotes a crypto asset security [or any other security] must 246'