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 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.
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.
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.
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.