Kuvera Global Review: Investview still flaunting securities in front of SEC
On March 1st, 2018, parent company Investview announced Wealth Generators was changing its name to Kuvera.
Wealth Generators began as a stock investment advice opportunity. In late 2017 the company began offering cryptocurrency mining contracts.
Wealth Generators affiliates invested up to $4999 in individual mining contracts, on the promise of an advertised 1200 day ROI.
Investview and Wealth Generators differed from your usual MLM unregistered securities offering, in that Investview is actually registered with the SEC.
Analysis of the company’s required regulatory filings as of December 2017 however, revealed no mention of Wealth Generators’ passive ROI crypto mining offering.
This lead me to conclude that, despite Investview being registered with the SEC, Wealth Generator’s “Crypto” cloud mining product was still an unregistered security.
Whether this had anything to do with Investview renaming Wealth Generators to Kuvera is unclear.
The Kuvera MLM opportunity has since been branded Kuvera Global. The service side of Kuvera operates as Kuvera Wealth.
Kuvera Global cite Ryan Smith as Founder and CEO of the company.
Ryan has over 20 years of experience in business management and in the financial markets.
Prior to founding Kuvera, Ryan co-founded a brokerage firm and eventually focused of teaching others how to trade in the markets successfully – literally bringing “Wall Street to Main Street.”
With roughly six months having passed since we examined the Wealth Generators securities question, today we take a look at where Kuvera Global is at.
Kuvera Global Products
Through Kuvera Wealth, Kuvera Global continue to offer cryptocurrency mining contracts.
Kuvera offers state of the art mining leases of various hash rates. If you want a way to make money in the crypto industry with a Set-It And Forget-It program, mining is your answer.
Get deposits in your account weekly.
Kuvera Wealth’s mining contracts mirror that of Wealth Generators;
- Generator – $499.99
- Business – $999.99
- Executive – $2499.99
- Premier – $4999.99
Secret $25,000 “VIP mining programs” are also available, the details of which are not disclosed on the Kuvera Wealth website.
Whereas Wealth Generators had a 1200 day ROI hard cap however, Kuvera Wealth’s contracts are open-ended.
Each mining contract is guarenteed [sic] for 1000 days but will last the lifetime of the equipment past the 1000 days.
Strangely enough, there doesn’t appear to by any mention of cryptocurrency mining contracts on the Kuvera Global website.
The only two products listed are “Financial Fitness” and “Market Education”.
Financial Fitness provides “money management” advice pertaining to personal finance and tax preparation.
Market Education is a newsletter subscription for stock investment advice.
The product page separates Financial Fitness and Market Education into three price-points:
- CryptoOne – “Crypto Education, Analysis, Research, CRYPTO Alerts, University, Money, and Deductr”, $20 and then $169.99 a month
- FXone Pack – “Includes Live FX Trading Sessions, FX Trade Alerts, Money, University, and Deductr”, $30 and then $179.99 a month
An “All In Pack” combines everything plus the Ryze auto-trading investment service for $30 and then $229.99 a month.
Why the Kuvera Wealth cryptocurrency mining packages aren’t listed on the Kuvera Global website is unclear.
The Kuvera Global Compensation Plan
In addition to cryptocurrency mining ROI payments, Kuvera Global affiliates are paid on the sale of monthly subscriptions.
These commissions are tracked via a unilevel compensation structure.
A unilevel compensation structure places an affiliate at the top of a unilevel team, with every personally recruited affiliate placed directly under them (level 1):
If any level 1 affiliates recruit new affiliates, they are placed on level 2 of the original affiliate’s unilevel team.
If any level 2 affiliates recruit new affiliates, they are placed on level 3 and so on and so forth down a theoretical infinite number of levels.
Kuvera track sales volume generated throughout a unilevel team.
Sales volume (GV) is made up of subscription sales to retail customers and recruited unilevel team affiliates.
- CryptoOne and FXone subscription = 100 GV (monthly recurring)
- Generator mining contract ($499.99) = 100 GV
- Business mining contract ($999.99) = 200 GV
- Executive mining contract ($2499.99) = 400 GV
- Premier mining contract ($4999.99) = 800 GV
Based on monthly unilevel team sales volume generation, Kuvera Global affiliates are paid the following monthly commission rates:
- Business Builder – generate 1900 GV a month (max 950 GV from any one unilevel leg) and receive $300 to $350
- Executive – generate 6000 GV a month (max 3000 GV from any one unilevel leg) and receive $800 to $850
- Premiere – generate 15,000 GV a month (max 7500 GV from any one unilevel leg) and receive $1800 to $1850
- Platinum – generate 25,000 GV a month (max 9375 GV from any one unilevel leg) and receive $4300 to $4350
- Global Platinum – generate 50,000 GV a month (max 18,750 GV from any one unilevel leg) and receive $8800 to $8850
- Presidential – generate 100,000 GV a month (max 37,500 GV from any one unilevel leg) and receive $14,800 to $14,850
- Elite Presidential – generate 200,000 GV a month (max 75,000 GV from any one unilevel leg) and receive $24,800 to $24,850
- Ambassador – generate 350,000 GV a month (max 131,250 GV from any one unilevel leg) and receive $44,800 to $44,850
- Global Ambassador – generate 500,000 GV a month (max 187,500 GV from any one unilevel leg) and receive $64,800 to $64,850
- Icon – generate 750,000 GV a month (max 281,250 GV from any one unilevel leg) and receive $89,800 to $89,850
- Legend – generate 1,000,000 GV a month (max 375,000 GV from any one unilevel leg) and receive $119,800 to $119,850
- Global Legend – generate 1,500,000 GV a month (max 562,500 GV from any one unilevel leg) and receive $159,800 to $159,850
- Pinnacle – generate 2,000,000 GV a month (max 750,000 GV from any one unilevel leg) and receive $219,800 to $219,850
- Elite Pinnacle – generate 3,000,000 GV a month (max 1,112,500 GV from any one unilevel leg) and receive $349,800 to $349,850
I’ve provided the quoted $50 difference in payouts at each level verbatim from the Kuvera Global compensation plan.
Unless I’m missing something obvious no explanation for the $50 difference is provided.
Luxury Bonuses
Kuvera Global reward affiliates earning at the Premiere commission tier and higher with the following Luxury Bonuses:
- Premiere – an Apple iPad or iWatch
- Platinum – a “custom ring” or Kate Spade bag
- Global Platinum – a “custom suit” or “shopping spree
- Presidential – a MacBook Air or Tiffany diamond earrings
- Elite Presidential – $3000 in crypto contracts
- Ambassador – an “all inclusive trip for you and a guest”
- Global Ambassador – a Rolex watch or $8000 in gold
- Icon – a “Rzr” (???), $15,000 in cash or a Cartier Love bracelet
- Legend – a “luxury car of your choice up to $80,000 in value”
Joining Kuvera Global
Kuvera Global affiliate membership is $50.
Conclusion
There’s little differentiating Kuvera Global from Wealth Generators. Which is to be expected I guess, seeing as Investview acknowledged it was only a name-change.
On the regulatory front what we’re looking for is disclosure of the Kuvera Wealth cryptocurrency mining opportunity in Investview’s SEC filings.
The last filing Investview made was on April 17th, which was to formally acknowledge the Wealth Generators to Kuvera name-change.
In the filing before that, dated March 8th, here’s how Investview described it’s MLM operations;
About Wealth Generators/Kuvera LLC
Wealth Generators/Kuvera provides financial technology, education, and research to individuals to enable them to “Find, Grow, and Keep” their money.
We are best described as a financial fitness company providing our customers the tools and information that can improve their financial situation.
Wealth Generators/Kuvera products are distributed through a direct sales model. Our products are offered to individuals on a monthly subscription basis.
Wealth Generators/Kuvera is classified as a publisher of financial research and information and exempt from securities registration.
This is an exemption provided in the U.S. Securities Investment Advisers Act of 1940.
Wealth Generators/Kuvera is not a brokerage firm or Registered Investment Advisor.
We do not execute trades or take possession of clients’ brokerage accounts.
Our customers may cancel their subscription at any time and execute trades at their own discretion.
There is no mention of Kuvera’s cryptocurrency mining contracts anywhere in the filing.
I’ve bolded why Investview might feel they don’t need to disclose their mining contracts to the SEC above, however that seems to only pertain to their monthly subscription services.
Kuvera Wealth’s contracts have nothing to do with the monthly subscriptions.
And make no mistake, in every sense of the word, Kuvera Wealth’s mining contracts are very much a securities offering. And they make no attempt to hide it.
Once you setup your mining contract you will begin recieving [sic] deposits EVERY WEEK without any work. It is essentially set-it and forget-it.
Maximize your investment
One way to maximize your mining investment is to keep reinvesting your profits in more mining contracts.
As you gain more contracts you make more and more crypto faster and faster every time.
I went through every Investview filing since our December 2017 report and found only one reference to cryptocurrency mining;
We provide education, and technology designed to assist individuals in successfully navigating the financial markets.
Our services include research, newsletter alerts, and live education rooms that provide instruction on the subjects of equities, options, forex, exchange-traded funds, binary options, and crowdfunding.
In addition to tools and research, we offer education and technology applications to assist individuals in debt reduction, increased savings, budgeting, and proper tax expense management.
Most recently, we have added cryptocurrency education and access to mining services.
Seriously, that’s it. No specifics, no disclosures, no nothing.
All the more pertinent is Investview boasting about increasing revenue, which coincides with the introduction of the cryptocurrency mining packages.
For the record, Investview managed to come out of 2017 with a net loss of $7.1 million for the fourth quarter.
If I’m understanding correctly, Investview are failing to disclose their cryptocurrency mining securities offering to the SEC, on the basis they aren’t auto-trading with respect to their stock signals service.
Seriously?
It doesn’t matter what else Investview are or aren’t doing, their Kuvera Wealth cryptocurrency mining contracts are generating passive returns for investors – and that needs to be disclosed as a securities offering.
How long this is going to go unnoticed by the SEC I can’t say. Securities fraud taking place right under the regulator’s nose surely isn’t a good look.
With respect to the rest of Kuvera Global’s compensation plan, it’s basic but actually pretty decent.
Commissions are tied to sales volume, which is ideally a combination of retail customer and affiliate purchases.
Unfortunately though there’s no retail requirements built into the compensation plan. Meaning if affiliates are the primary source of sales revenue, Kuvera Global is operating as a pyramid scheme.
There is a product credit attempt that rewards affiliates and retail customers for bringing in new customers (affiliates or retail customers), but the lack of differentiation with respect to retail customers or affiliate purchases does nothing specifically to encourage retail sales.
This is of course dwarfed by the crypto mining securities fraud issue, so I don’t feel the need to elaborate any further.
In a nutshell: publicly traded company + unregistered securities = disaster waiting to happen.
One interesting point to note, Investview/Kuvera purport that you are not buying into a cloud mining pool but rather that you’re getting more or less a lifetime lease on individual pieces of mining hardware.
If I were a churlish skeptic I’d be tempted to think the offer is expressed that way to thwart the Common Enterprise prong of the Howey test.
If I’m right they’re still wrong.
Look up 1946’s SEC v. W.J. Howey Co. Howey owned extensive orange groves in Florida and investors would buy contracts which allowed then to share in the profits their portion of the groves produced.
The contracts were most commonly denominated in acres or portions thereof.
Unless theres a substantial legal difference between the profits from an individual piece of mining hardware and and the profits from an individual acre of orange grove then a fear Investview’s artifice will fail.
This of course presumes that the Common Enterprise prong of the Howey test applies to W.J. Howey.
They say they are not pooling.
When you look at the mining results being distributed for each contract size everyone is getting the same deposits.
Seems to me if you are legitimately mining separate machines you wouldn’t be generating the same results.
Unless they are pooling all the mining results together and maybe not the machines.
They are still pooling, which isn’t that considered a security according to the SEC?
@Glim
Purport isn’t good enough. If they want to claim that, fine. But provide audited accounting for every machine and include those reports in their SEC filings.
If Investview aren’t going to provide disclosure in their filings then as far as anyone knows affiliates are pooling funds in a common enterprise (Kuvera Global) on the promise of an advertised passive ROI.
How many MLM companies have we seen taken down for lack of disclosure over the past six months? And here’s Investview, registered with the SEC no less, doing the exact same thing.
@Oz the mining contracts originally had audit rights for the customers. The way it read, you could audit the records or facilities. However I’ve yet to see a single customer do an audit.
The video provided by the company doesn’t substantiate the accounting for the machines or validate they are not pooling.
Just an undisclosed building and location with mining equipment that have Kuvera stickers, because stickers make everything legit : )
@Mark
The onus isn’t on Kuvera Global’s investors to request individual audits, the onus is on Investview to make full disclosure of their mining investment opportunity in their SEC filings.
@Oz
I agree.
A 10-Q was filed in February and it mentions but does not explain their crypto mining offering.
seekingalpha.com/filing/3885674
Of note they claim mining income (in the fourth quarter of 2017) of $1,336,895 and “Amounts paid to supplier” for mining of $796,889, almost 60% of that income is paid back to company in Romania that does their mining.
It’s somewhat confusing but I believe that mining income number may come from subscribers instead of or in addition to any mining Investview does:
They do accept crypto as a form of payment and again, this report is from the forth quarter of 2017 when Bitcoin hit $20K, now it’s near 1/4 of that. It will be interesting to see how that affects their bottom line.
So yes, Investview is disclosing their mining service but in no way attempt to to describe how it works. We’ll see how fast and loose with the facts plays out for them.
And just a few hours ago their annual report dropped, bonus content, it includes the first quarter of 2018 as well.
ih.advfn.com/p.php?pid=nmona&article=77776579
I’m still combing through it, there are some formatting errors that make some of the charts hard to read but a few interesting footnotes:
It never comes as any surprise to see Alex Morton’s name included in a lawsuit.
“.,..and will agree not to act as an unregistered Commodities Trading Advisor in the future..,.” ???
Innvestview sells education packages and they don’t need to be registered for that, that’s what they have been telling us for years.
I honestly do not know if the subpoena they received has anything to do with their crypto mining product but if they did get in trouble for that it would be the CFTC that would jump on them.
Thanks for the heads up. Looks like I’ve got some research to do today.
Killing my Saturday morning vibes :).
Looks like more “corporate espionage” at work with Brandon Boyd talking about possibly working with Kuvera’s top distributor Anthony Napolitano in the future.
Brandon Boyd shared this post on June 2nd of this year.
facebook.com/photo.php?fbid=1176210259183641
I’m sure attorney’s are loving this.
Kuvera has been selling much larger contracts above $4999.99.
You can see in Travis Flaherty’s youtube videos pitching large VIP services of $25,000 on up.
See videos: youtu.be/UijJLJ3RU0M?t=23m18s
I’ve done some digging and several people have purchased $50,000 to $150,000 mining contracts. These people have been presented a spreadsheet that projects the earnings over the next 12 to 36 months.
They are calling them maximizers.
I’m sure regulators are stacking the evidence.
@Oz,
This maybe worth a separate review: youtube.com/watch?v=AtoYXVtA46c
Kenny Gardner and John Lavenia review passive income with Kuvera. Kenny seems pretty confident after bashing companies for months.
“Crypto veterans” aren’t pushing unregistered securities schemes like Kuvera Global.
Hour and a half? Pass… because I’m pretty sure the unregistered securities issue isn’t addressed, and that’s what the legitimacy of Kuvera comes down to.
A bit before the 36 minute mark of the video Laurie posted is kinda interesting. We see a sceen shot on Etherscan dot IO of a wallet named “Kuverapool.”
Needless to say that if Kuvera is operating a pooled wallet their “you are leasing your own individual pieces of mining equipment” ruse falls apart and any pretense of operating legally in the US dies with it.
I’m begging assistance from anyone who didn’t recently break their reading glasses and preferably also knows more than I do about searching for ETH wallets.
At the 35:58 mark in the video Laurie posted there’s a wallet address near the top of the screen. My thanks in advance for anyone who can find it on Etherscan.
Wallet: 0x4E4e23Ac3c11789e23169025503EA4373b01417b
etherscan.io/address/0x4E4e23Ac3c11789e23169025503EA4373b01417b
This seems to be their ROI payment wallet (run weekly):
etherscan.io/address/0xc6300135a8fcd43123bb486ff06831b5345d0971
Lulz, totally not pooled funds invested in a common enterprise.
I beg to differ here. If nothing else that that wallet has been involved in 408K transactions and I don’t think Kuvera can drive those numbers.
There are details here I simpley don’t understand. We need a crypto expert here (Yo Tim !!!).
One withdrawal = one transaction.
Over ~90 days you’re looking at ~31,733 withdrawal requests a week.
Take into consideration zero fees, multiple requests and affiliates holding multiple accounts/contracts and it’s not unimaginable.
Another possibility is that the unnamed account is owned by Westmyn (Bott).
It might be being used for ROI payments for multiple schemes?
Investview has just purchased United Games which was reviewed by Oz in June 2016…
Google United Games kuvera and you’ll find it..
Wonder if all they purchased was the affiliate-base to spam to. From memory United Games Marketing was a complete flop.
Did the app ever launch??..
I read somewhere that United Games is connected to nu skin..dont know if its true…I didn’t follow that closely.
I don’t think they ever launched the initial gambling app concept.
They eventually did launch FireFan but it doesn’t seem to have gone anywhere (Alexa ranking 1.6 mill).
The UGM website is still up, although what they’re marketing now is completely different to the initial concept:
Just another “use apps we provide and we’ll pay you” failed opportunity.
They have stolen over 10K US from their bogus crypto mining contract and autotrading BOT called Rise in 2017 & 2018.
Anyone interested in joining a country wide lawsuit against this scam company email me at (removed). They are going down.
R. Smith,
What is the status of the class action suit against Kuvera? I lost my $500 on their bogus ethereum mining contract in September 2018!