SEC v. Benjamin L. Bunker, Esq. (pump and dump, 2020)

Settled

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In January 2020 the Securities and Exchange Commission settled an administrative proceeding with attorney Benjamin L. Bunker, finding that between 2014 and 2016 he wrote false opinion letters letting two Greenway Design Group insiders obtain unlegended shares and sell them into a promotional campaign without registration. He was denied the privilege of appearing before the Commission and ordered to pay $1,800 in disgorgement and $249 in interest.

The record

What was ordered

Civil penalty

—

Disgorgement

$1.8k

Prejudgment interest

$249

Total relief

$2k

Alleged gain

—

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

What is alleged to have happened

the Securities and Exchange Commission announced this matter on January 23, 2020 as release 3-19668. The respondents named are Benjamin L. Bunker, Esq. (1 individual, 0 entities).

The order finds that Bunker's opinion letters falsely said that sales by the nominee and colleague of Greenway's undisclosed control person met a Securities Act registration exemption, which let the shares be sold into an artificially inflated market during a promotion. Greenway's later reverse merger is background only. This library tags the matter as pump and dump, undisclosed control blocks and unregistered distributions.

The conduct is recorded against equities, with OTC identified in the release.

The relief recorded in our data is disgorgement of $1,800, prejudgment interest of $249. Penalty and disgorgement are distinct: disgorgement returns the gain, while the penalty is punitive. We store them separately so that aggregate figures across the library are not double-counted.

For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the release.

What technique is this, and how does it work?

This action is tagged with 3 techniques in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.

• Pump and dump — see how it works, what statute it engages, and every other action tagged the same way.
• Undisclosed control blocks — see how it works, what statute it engages, and every other action tagged the same way.
• Unregistered distributions — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2020-01-23 Administrative proceeding instituted (102e)

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

• SEC order

The linked release is a work of the United States government and is not subject to copyright. Our summary and narrative above are our own writing.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added September 10, 2026. submit a correction.