Court filing
Exhibit Articles for sentencing purposes — USA v. Keough (Dkt. 54-1, S.D. Fla. No. 9:23-mj-08393, docketed in No. 9:23-cr-80154)
Filed February 6, 2024 in USA v. Keough; one of 55 filings from this case.
Record facts
| Court | U.S. District Court for the Southern District of Florida |
|---|---|
| Filed | 2024-02-06 |
U.S. District Court for the Southern District of Florida · No. 9:23-cr-80154-DMM · Doc. 54-1 · 2024-02-06 · Docket on CourtListener
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Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 1 of 38 Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 2 of 38 Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 3 of 38 Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 4 of 38 Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 5 of 38 Subscribe to newsletters Sign I n Three men and a Web idea Zina Moukheiber Former Contributor May 17, 1999,12:00am EDT A VENTURE CAPITALIST stops at Gregory Keough's booth during the Mid- Atlantic Venture Fair in Philadelphia -- an annual meat market for money- hungry entrepreneurs. He stares at a computer screen, looking stumped. Keough's Web site is in Spanish, and the VC can't read a word. "We're Zona Financiera," Greg says, rolling his "r" in perfect Spanish. "The on-line financial services provider to Latin America." The financier sizes him up: 32-year-old Keough is about as Latino-looking as Matt Damon. "How the hell did a gringo like you get involved with a thing like this?" the VC wants to know. Greg clears his throat and drops a small bombshell: He was an officer in the Central Intelligence Agency in Latin America during the early 1990s. "I'm afraid I can't say more," he teases. A line in his rsum reads intriguingly: "Acted as contact between the U.S. and rebel forces and extreme right-wing political factions." Those dangerous liaisons, he claims, earned him the agency's highest award, the Intelligence Star. Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 6 of 38 The financier is curious, but he shakes his head. "Don't know much about those [Latin American] cultures," he confesses. Greg sighs as the visitor departs, "This is harder than I thought." It's a damp day in mid-November 1998. Greg and his brothers Jonathan, 27, and Timothy, 25, are among 98 entrepreneurs in Philly's convention center. They're all vying for the eye of potential investors, who mill about the booths like traders in a Middle Eastern bazaar. For the Keoughs, it's a stop on a 15- month journey to find startup capital. The idea is to offer a place where Spanish- and Portuguese-speaking denizens of the Net -- 10 million and counting -- can comparison-shop for a mortgage, a car loan or insurance, as well as check stock quots and financial news. Latin America's total loan volume outstanding, Keough claims, is more than $1 trillion, none of it transacted on-line. (In the U.S. less than 1% of loans are done that way.) Keough aims to collect a flat fee of $10 on loan leads to banks, and a 0.25% cut if the borrower applies on-line. To participate, banks like BankBoston (Zona's only customer so far) pay a $5,000 fee per country. Keough is nearly hoarse from reciting his spiel to mildly interested passersby. It's the siren song of every entrepreneur in need of cash: confident, upbeat, masking desperation. The money hunt is an exhausting test of persuasion and raw staying power. Keough is looking for $1 million, mainly to attract management. He has already hit a wall. Before Zona, Greg and his brothers sank $200,000 of their savings into a loan-quoting engine for U.S. home buyers. But they were slow to forge ties with portals to promote their Loan Locator and got bumped by Intuit, which shelled out $30 million in part to be America Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 7 of 38 Online's loan channel. "You can have a Web site that turns lead into gold," muses Keough. "But if people don't know you're there, you're out of business." Not a total loss: The Keoughs ended up licensing the loan-quoting technology for $600,000 to a couple of financial services firms, and plowed two-thirds of the proceeds into Zona in December 1997. Jonathan (who managed AOL Canada's Web site) and Tim (who helped develop Intuit's site) created the technology. They set up shop in the tight storage room of their parents' home in Potomac, Md. and hooked up a T-1 line. But just try to interest a venture capitalist. "Come back when you get financing," one investor told Keough. Just the day before the fair, they'd driven 13 hours from Charleston, S.C., where Keough gave a presentation to a group of uninspired VCs. Now he has to do it all over again in front of a hundred potential investors busy digesting a three-course lunch. Behind him, in big letters, "Financiera" is misspelled. Keough ignores it and cracks a joke: "Getting money from this crowd would be like getting an award from the CIA." A few titters. Keough effortlessly rattles off his pitch, coming in at seven minutes -- three minutes less than his allotted time. The audience appreciates brevity; it has to listen to 49 other presenters. Afterward Michael Faber approaches Keough. "What impresses me is when an entrepreneur speaks clearly and passionately," he says. Faber manages a $10 million fund in Washington, D.C. that invests in Internet start- ups. He hands Keough his business card. Discreetly, Keough scribbles an "8" on the back. It's his rating system for gauging the level of investor interest on a Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 8 of 38 scale of 0 to 10. "Nobody's going to remember who said what at the end of the day," he says, his blue eyes showing fatigue. It's 5:30, time for his appointment with Karen Griffith Gryga, a partner with Philadelphia-based Liberty Advisors. Arriving ten minutes late, Griffith Gryga creates a small sensation when she shows up at Zona's booth -- long, platinum blonde hair cascading over the faux leopard fur collar of her dress, diamond studs the size of peas poking through her ears. Zona caught the eye of the 33- year-old venture capitalist at a similar venture fair in Virginia last September. "I'm guilty," she confesses, settling into a chair. "I read your business plan. So, what's your lesson with the Loan Locator?" Distribution deals are key, Keough answers quickly. It's also important to be first. Amazon, for instance, was successful because it got in when Internet real estate was cheap. Zona has that opportunity now in Latin America, land of 500 million potentially wired souls, where the Internet landscape is still virgin. "Only 2% of all Web sites are in Spanish or Portuguese," he notes. "The big kicker is going to be StarMedia," Keough says, referring to the portal that's shaping up as the Yahoo of Latin America. StarMedia has raised a total of $80 million in private placement funding. Zona just inked a deal to be the provider of financial news, real estate listings and loan rates on StarMedia's money page. Greg plays the relationship to the hilt. But Griffith Gryga isn't biting. Keough never hears from her again. "You have to understand what's going on in these countries, and I don't," she later explains. Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 9 of 38 Mike Faber, who rated an "8" on the business card, calls the next day. So does Stephen Walker, an investor from Glenwood, Md., whom Greg met in October. Walker sold his network security company to Network Associates, and is now looking to play angel. "I wasn't sure what [Zona] was all about, but Greg sounded so good at what he was doing, and he was creating something that nobody had done before," recalls Walker. "I thought, 'Let's throw some money at these guys.'" Meantime, Keough is trying to add luster to Zona by getting former vice presidential contender Jack Kemp to chair its advisory board. Keough approaches a family friend who knows Kemp, and can put in a good word. At their first meeting in Kemp's downtown D.C. office, an excited Keough expounds on his plans to partner with local media powerhouses. He points out that Chile's La Tercera and Venezuela's El Universal are already providing local financial news. Kemp listens intently. He speaks a smattering of Spanish (his mother taught the language in Los Angeles) and, as an early supporter of NAFTA, knows Latin America well. He's also friendly with Argentina's former Finance Minister Domingo Cavallo and Pedro Aspe, former finance minister of Mexico. Kemp, who sits on the boards of Oracle and Proxicom, a Web-site design company, is especially impressed with Keough. "He's a go-getter," he says. But in early December two offers to buy Zona take Keough by surprise. Portal companies he won't name are dangling between $4 million and $8 million. It's tempting. Should he sell out? Keough pays a call on Walker, looking for advice. "Steve, you started out in a basement like us, what would Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 10 of 38 you do?" he implores. "My advice is either focus on growing the company -- or selling it, but don't dilly-dally," replies Walker, who's still thinking of investing, but doesn't want Keough to take his money just to tide him over until he sells. Thoroughly conflicted, Keough stalls for a month, wondering what to do. Then it hits him: "Heck, if those people are interested in us, and think we're worth that much now, we must be doing something right." Why sell out for less now when there was a good chance to get a lot more money down the road? By Christmas things start to come together. Walker and Faber eventually chip in a total of $350,000 -- and Walker provides entre to Capital Investors, a blue-ribbon group of angels in Washington, D.C. that includes AOL's Stephen Case, John Sidgmore, vice chairman of MCI WorldCom, and William Melton, chief executive of Cybercash. Each has thrown at least $100,000 into a pot for seed investments. Keough will make his case before the club on Jan. 11. That night he gets behind the wheel of his blue BMW 318is. "Guys, don't forget to bring business cards!" Greg hollers to Jonathan and Tim, slipping in a tape of Ricardo Arjona, the Guatemalan Springsteen. After a quick supper at a tapas bar, they head to D.C. Coast, a swank downtown restaurant. There, Walker ushers them into a private dining room downstairs, where 12 members of Capital Investors are still polishing off their chocolate cake and crme brle. Dressed in khakis and blue, button-down shirts, the Keoughs take a seat. If Greg is nervous, he doesn't show it as he begins a 20-minute presentation. After only a couple of minutes, the questions start coming. "What's the status of ISPs?" asks John Burton, former chief executive of Legent Corp., a data software company that's now part of Computer Associates. Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 11 of 38 Phone service is often more expensive in Latin America, but Keough parries, "The good news is that people who want to monitor their finances have money." "[Gustavo] Cisneros has some pretty strong views about dominating the Internet in Latin America," says veteran angel David Gladstone. "Where do you think you'll end up?" "It's the best company to partner with," replies Keough, without mentioning he's had talks with the Venezuelan media mogul's company. That's because he's gotten nowhere yet. He quickly continues: "The great advantage is that companies like Yahoo and AOL don't want to build from scratch. We can go and say, 'Hey, do you want a turnkey solution to a really good finance channel?' "We're ultraparanoid," he concludes. "We want to move as quickly as possible to build this thing up. We have a good opportunity to control on-line finance in Latin America." After the brothers leave, the angels decide to put in $500,000, in return for one-quarter of Zona. "Hey, heard it went pretty well," says Kemp in a phone call the next day. But Keough isn't happy. Capital Investors' offer values his company at a paltry $2 million. Counters Jeffrey Tonkel, president of Capital Investors, "You had three brothers in a basement with a T-1 line who'd made some progress in making contacts -- how do you value that?" Over the phone two weeks later, Keough offers Tonkel the terms of a convertible note -- a $500,000 loan with an option to convert at a discount at the next round of funding. He wants Zona valued at no less than $5 million. Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 12 of 38 The haggling goes on for more than a month. Tonkel hates convertibles. "It's an awful, awful security," he says. "What it really does is drive up the valuation for the early investors." In March he finally agrees to Keough's demands, but caps Zona's valuation at $3.5 million. He offers $300,000 for notes convertible at 50% of the next financing, giving Capital, Walker and Faber a total 18.5% stake in Zona. Keough is $350,000 shy of his original goal of $1 million. But he now has a team of heavy hitters -- and has gotten over the first big hump. The brothers finally move into an office in Falls Church, Va., in the heart of a Latin American neighborhood. In April Keough signs on with Microsoft to provide financial news for MSN Latin America, and is discussing deals with potential bank sponsors, including Citigroup. Now for the tough part. Greg has spent the past several weeks on the road, opening offices in Mexico City, Buenos Aires, Santiago, Bogot and So Paulo, and hiring country managers to beef up Zona's content -- and to sign up more sponsors. Now he has to hit the VC circuit once again for a second round of financing. This time he's hoping to raise $7 million. If Wall Street's infatuation with the Web continues, he can get it. But it might end. One day in mid-April Amazon was off 31 points. Most executives just have to worry about the competition. The Keoughs also have to worry about whether they can get desperately needed capital before the bottom falls out. Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 13 of 38 Zina Moukheiber I initiated regular coverage of the biotech industry at Forbes, and wrote many of the early stories on genomics, personalized medicine, Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 14 of 38 Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 15 of 38 Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 16 of 38 Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 17 of 38 In Profile Name: AperServ Technologies Inc. Location: Vienna Big idea: Software and services that help companies monitor computer systems for potential glitches. Launch date: Founded in March, the company's products will be officially launched and available to clients today. Who's in charge: Gregory S. Keough, 34, founder and chief executive; Timothy B. Keough, 28, founder and chief technology officer. Previous jobs: The Keough founded Virtual Loan Corp., an online mortgage firm, and then ZonaFinanciera.com, a personal-finance Web site for Spanish and Portuguese speakers. Before striking out on their own, Gregory Keough was an operations officer with the CIA, and Timothy Keough was an analyst with Andersen Consulting (since renamed Accenture Ltd.). Big name advisers: James J. Condon, the former chief executive of bankrupt CyberCash Inc. and entrepreneur in residence at Updata Venture Capital; Gina Dubbe, managing partner at Walker Ventures; Ed Horowitz, former chairman of e-Citi, an Internet-focused unit of Citigroup Inc. Funding: In March the company landed $1.4 million in venture capital from Lycos Ventures, Walker Ventures and the Maryland Angels Council. Employees: 17 High-profile clients testing the service: The National Geographic Society, Discovery Communications and Lycos. Slogan: Someone watching out for you. Company culture: Familiarity. Each of the employees has worked with at least one other employee at a previous job. Lesson learned: Efficiency is key. The firm is maintaining a lean budget; the employees sit on $5 chairs. They're fine chairs, said Gregory Keough, just a little used. Entrepreneurial roots: Each of the Keough brothers (There are four.) paid his own way through college. "We were always selling weird things and getting into lawn [care] businesses," Gregory Keough said. Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 18 of 38 Meaning of the company name: AperServ is short for "a perfect service." https://www.washingtonpost.com/archive/business/2001/07/23/in- profile/ff2afb70-d6d5-456a-a3cf-613c6b408434/ Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 19 of 38 RegaloCard Changes Its Mobile Funds- Transfer Process March 16, 2010, 3:13 p.m. EDT2 Min Read RegaloCard, a fledging mobile-payments company that soon plans a nationwide rollout in the United States, has changed how consumers send funds transfers using its free product. Under the new system, senders purchase a merchant’s prepaid card and scratch off an area on the back of it to reveal a PIN. The buyer then calls a toll-free number and enters the PIN and the recipient’s mobile number. The recipient receives an instant text message that contains a redemption PIN to use to access and use the funds at the specified retailer. The recipient receives a text message instantly that contains a redemption PIN so he can use the funds at a participating retailer. To complete a transaction, the cashier enters the recipient’s mobile-phone Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 20 of 38 number into a dedicated terminal. The recipient then enters the PIN to access the funds. That process remains unchanged. The previous system required senders to purchase a prepaid gift card in the United States for a specific retailer in Central America. When the consumer bought the card, he told the cashier the recipient’s name and cell-phone number, which the cashier entered into RegaloCard’s back-end system using software integrated into the point-of-sale system. The cashier then gave the sender a “unique code” that served as a tracking number for the transaction. RegaloCard believes the new method will help the company attract more interest in the service, according to Gregory Keough, chairman and CEO of the Miami-based company. The system works with any cellular carrier and phone. The company’s distribution network is scattered across the United States, but consumers may purchase cards at locations that also sell prepaid phone cards, such as convenience stores in parts of New York, California and Nevada. RegaloCard plans to announce additional distributors in the next couple of weeks, Keough says. During a seven-month trial that began last summer, consumers suggested the new system to RegaloCard. It was a process the company had on the backburner because it resembled the way consumers bought prepaid calling cards, Keough says. “We wanted to stay as close as possible to normal consumer behavior,” he adds. RegaloCard continues to grow its retail network in Central America. At least eight retailers accept RegaloCard in El Salvador. In Guatemala, department store chain Cemaco also accepts RegaloCard payments. The chain has 10 locations that sell household goods, such as furniture and kitchen appliances. Locations in El Salvador include Burger King and Chili’s Bar & Grill. Keough believes RegaloCard has created a market for a funds-transfer option that previously was unavailable. The company has dubbed it the “micro-money transfer.” Consumers can send as little as $10, but RegaloCard may reduce the amount to $5. RegaloCard receives a percentage of the funds loaded into the card accounts from each participating retailer. “We’re fundamentally changing a very large business in money transfers, but at the end of the day our business concept is simple and easy to understand,” Keough told PaymentsSource in January. Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 21 of 38 Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 22 of 38 Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 23 of 38 Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 24 of 38 A s the CEO of a joint venture between MasterCard and Telefónica, Gregory Keough would often head over to his Florida farm to relax after a hard day‟s work and check up on his 25-acres of chipilin bushes, a wild herb pri- marily used in tamales. One afternoon, one his em- ployees rushed over to him, breathlessly asking to bor- row $1,750 to pay off a loan that had more than 300 per- cent interest. That was the day that com- pletely altered Keough‟s life. He discovered a $138 billion- dollar U.S. crisis -- and its victims are many hard- working Americans facing a temporary cash shortage. He also discovered that almost 50 percent of the U.S. population can‟t cover a $400 emergency expense without borrowing money or selling something. “These folks are among the 70 million Ameri- cans outside of the financial system who end up spending $138 billion in fees and interest annu- ally on emergency-loan services like auto-title lenders,” Keough says. So, in response to this crisis, he created Finova Financial, a so- cially-conscious online company geared to help save this seg- ment of the pop- ulation from falling deeper into poverty and debt. Welcome to the new era of af- fordable emer- gency loans of $500 or more. The platform has become an over- night sensation – so much so that Finova was named to the World‟s 100 Leading Finan- cial Technology Innovators. It also captured “Game Changer of the Year” by ACQ5 Global, which celebrates the achieve- ment and innovation of organizations and indi- viduals who have a significant impact in their industry and represent the benchmark of Financial Innovations California Business Journal / March 2017 / www.calbizjournal.com Problem Solver When Gregory Keough discovered that almost 50 percent of the U.S. population can’t cover a $400 emergency expense without borrowing money or selling something, he didn’t wait for the next person to do something about it. He did it himself. By Rick Weinberg, California Business Journal Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 25 of 38 achievement, professionalism and best practic- es. Additionally, Keough, a recipient of the Central Intelligence Agency's Intelligence Star Medal for extraordinary courage in the line of duty, was a finalist in Ernst and Young's Entrepre- neur of the Year Awards Program, as well as Washington's Top Technology and Internation- al Leaders and Latin America‟s Top Banker of the Year. “There‟s a lot of people living paycheck-to- paycheck and they‟re the ones who are hit the hardest when faced with a financial emergen- cy,” Keough says. “I wanted to find a way to help these people get back to better financial health and provide a more fair and affordable option.” T raditional terms are structured to basi- cally punish consumers, virtually guaranteeing that it will take, on aver- age, eight months to repay even a “30- day” loan. “And the fees and interest far outstrip the origi- nal loan amount,” Keough says. “By the time my employee asked me for the $1,750, he was already eight months into it – he made eight interest-only payments and still owed the origi- nal $1,750.” The people who have no option but to sign off on these kinds of emergency loans can least afford to pay such astronomical rates, yet the industry took advantage of them and created a vicious cycle of financial need and indebted- ness. “When I saw what was going on and how it af- fected my employee and others like him, I thought, „There has to be a better way. Let‟s forget about how it works now and let‟s think about how it could work.‟” Finova‟s loans cost up to 70% less than the cur- rent national average, providing instant access to capital, and a 12-month repayment pathway back to financial health. The industry-first, all- web loan model utilizes an individual‟s car as collateral for the loan. Finova just unveiled its platform in California, where eight percent of the population are “unbanked and historically lacking access to affordable credit,” Keough says. “The average borrower will pay more in fees and penalties than the original principal borrowed. It‟s dis- graceful and it had to change.” Copyright © 2017 California Business Jour- nal. All Rights Reserved. Financial Innovations California Business Journal / March 2017 / www.calbizjournal.com Finova Financial 4521 PGA Blvd. Suite 226 Palm Beach Gardens, Fla. 33418 844-576-0862 FinovaFinancial.com The Finova Team: (L to R) Juan Ramirez, CFO; Gregory Keough, CEO; co-founder Derek Acree, COO; Alfredo Rosing, CMO. Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 26 of 38 FINANCE MONTHLY FINTECH AWARDS 2018 41 ABOUT GREGORY KEOUGH LENDING INNOVATION FIRM OF THE YEAR Gregory Keough is co-founder and CEO of social impact/Fintech 100 List startup Finova Financial, which has earned consumer protection agency endorsement and was named Lending Innovation Firm of the Year/ USA by Finance Monthly. Mr. Keough has been extremely successful over the past 25 years in building world-class companies that use innovative technology to expand cost-effective financial services to consumers in the US and globally. His knowledge of technology, financial services, and in particular, increasing financial inclusion for the unbanked were the basis for forming Finova. Before joining Finova, Mr. Keough was the CEO of MFS (Mobile Financial Services, based in Miami) a joint venture created by MasterCard and Telefonica to develop mobile financial solutions that accelerate financial inclusion for customers in 12 countries in Latin America. Prior to that he was the Founder and CEO of RegaloCard, where he developed a global mobile payments company that offered a free and instant replacement to costly money transfer services. One of the few living recipients of the Central Intelligence Agency’s (CIA’s) Intelligence Star Medal for extraordinary courage in the line of duty, Keough was a finalist for Ernst and Young’s Entrepreneur of the Year and recognized as Washington’s Top Technology and International Leaders, Latin America Top Banker of the Year, and others. He is a graduate of Syracuse University and Harvard University’s Strategic Leadership in Inclusive Finance Program. The Finova Financial socially responsible and affordable lending model is designed to help borrowers with the cash they need now while also helping them establish better credit for future financial success. Finova Financial was founded in 2015 in response to the problem of predatory lending: There’s a “poverty penalty” for 70 million Americans who are unbanked or underbanked, 26 million who are “credit invisible,” and can’t come up with quick cash for an emergency expense. The underserved consumer base has been growing at 9% per year since 2011. One in 10 adults do not have any credit history with a nationwide consumer reporting agency, making acquiring credit extremely difficult. Yet half of all Americans report that they could not come up with $600 for an emergency expense without selling something or getting a loan. This has created a very vulnerable segment of the American population whose disenfranchisement and misfortune is being preyed upon by an unscrupulous emergency lending industry that offers short-term payday and auto title loans at sky-high prices that create deliberate debt traps. These loans are sold as 30-day or 60-day loans, but structured in such a way that they actually take, on average, 8 months to fully repay and the borrower ends up paying more than double the amount of the loan in interest and fees. The average interest rate on these loans is 300% but can run as high as 1,000%. Finova believes that hardworking Americans don’t deserve to get caught in these debt traps that only create more financial emergencies and hardship, so it created the industry’s first online and mobile auto title lending platform. Finova’s Car Equity Line of Credit (C-LOC) offers: • Interest rates maxed out at 30% APR—as opposed to the industry average of 300%. • 12-month repayment plan, which is unique in the title lending industry. Most emergency loans are structured for repayment in 30 or 60 days, which is not much time to recover from a financial emergency. • 10-day grace period on payments, with no penalty fees. • A portion of every payment goes to the principal, so there’s no way a borrower can be 8 months into repaying their loan and still be paying only the interest. • Application and approval 24/7 online and via smart phone, so borrowers don’t have to take time off work and travel to a storefront lender where it may take hours to get approved. • Payments can be made online, via smart phone, or at 32,000 MoneyGram retail locations like CVS, Walmart, and Dollar General. • Borrowers can monitor and manage their loan online. • Reporting to major credit bureaus, so borrowers are establishing credit while repaying their loans. • Ongoing line of credit when needed in the future after successful repayment of the original loan. Because of its lending platform designed with the goal of helping consumers, Finova has been named to the Fintech 100 List and was chosen as Lending Innovation Firm of the Year/USA by Finance Monthly. Finova has also earned a consumer protection agency endorsement with a current rating of 4.58 out of 5 stars at Consumer Affairs. FIRM PROFILE USA Finova Financial Web: www.FinovaFinancial.com CONTACT DETAILS Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 27 of 38 Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 28 of 38 Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 29 of 38 Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 30 of 38 Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 31 of 38 Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 32 of 38 Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 33 of 38 Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 34 of 38 Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 35 of 38 Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 36 of 38 Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 37 of 38 Case 9:23-cr-80154-DMM Document 54-1 Entered on FLSD Docket 02/06/2024 Page 38 of 38
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