SEC v. Robin G. Charlet, Steven W. Sparks, Gregory J. Tuthill and Kirk D. Porter (unregistered distributions, 2017)
Settled
Checked against the primary document on October 4, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, with sampled and disputed records read a second time. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.
In January 2017 the SEC charged four unregistered brokers over sales of unregistered Couch Oil & Gas offerings that raised about $9.8 million. Kirk D. Porter agreed to settle on the day of filing, and a consent final judgment against Robin G. Charlet, filed in December 2017, imposed injunctions and a $5,000 penalty. Outcomes for Sparks and Tuthill were not found.
The record
| Agency | SEC |
|---|---|
| Release number | LR-23720 |
| Date filed | 2017-01-13 |
| Date resolved | 2017-12-06 |
| Status | settled |
| Criminal parallel | No |
| Defendants | Robin G. Charlet ; Steven W. Sparks ; Gregory J. Tuthill ; Kirk D. Porter |
| Cited as charged or alleged | Exchange Act s.15(a) ; Securities Act s.5 |
| Techniques | Unregistered distributions |
What was ordered
- Civil penalty
- $30k
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- $30k
- Alleged gain
- —
What is alleged to have happened
On January 13, 2017 the SEC filed a complaint in the Northern District of Texas against Robin G. Charlet, Steven W. Sparks, Gregory J. Tuthill and Kirk D. Porter, alleging they acted as unregistered brokers selling unregistered oil and gas offerings of Couch Oil & Gas that raised about $9.8 million. Porter agreed, subject to court approval, to an injunction, $323,508.91 in disgorgement and interest combined and a $25,000 penalty; the claims against the others continued at that date.
Outcome. A final judgment as to Charlet, filed December 6, 2017, records that he consented without admitting or denying the allegations. It permanently enjoins him from unregistered offers and sales and from acting as an unregistered broker, and orders a civil penalty of $5,000. The stored penalty of $30,000 adds Charlet's $5,000 to Porter's $25,000; Porter's figure comes from the January 2017 release announcing his agreement, and we did not open the court's judgment against him.
What the sources do not show: the final result for Sparks and Tuthill, which we did not find, so the status describes the resolved defendants only and the case may be unfinished for the other two. The release says the claims against Couch and Couch Oil were resolved earlier, by judgments of May 2016.
This library tags the matter as unregistered distributions, based on the conduct the documents describe. The tagging is ours, not the regulator's: agencies charge statutory provisions, not technique names.
What technique is this, and how does it work?
This action is tagged with one technique 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.
- Unregistered distributions — see how it works, what statute it engages, and every other action tagged the same way.
Timeline
- 2017-01-13 Litigation release published
- 2017-12-06 Consent final judgment against Charlet filed: injunctions and $5,000 civil penalty (Porter, Sparks and Tuthill not covered)
Primary documents
Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.
Related actions
Other actions in the library sharing at least one technique tag with this one.
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|---|---|---|---|---|---|
| SEC v. Zachary Miller (unregistered distributions, 2026) | SEC | 2026-03-05 | Unregistered Distributions | — | settled |
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| SEC v. Peter Scalise III and The3rdBevco Inc. (unregistered distributions, 2025) | SEC | 2025-06-17 | Unregistered Distributions | $236k | settled |
| SEC v. Investview, Inc. (unregistered distributions, 2025) | SEC | 2025-01-17 | Unregistered Distributions | $375k | settled |
| SEC v. Tai Mo Shan Limited (unregistered distributions, 2024) | SEC | 2024-12-20 | Unregistered Distributions | $36.7m | settled |