UPDATE: Web References, Images Linked To Investing Raise New Questions About PPE-Life; Records Suggest Recruitment Bids Started In January And That Promoters Referenced Warren Buffet

A video promotion for PPE-Life, which is facing a challenge for allegedly selling unregistered securities in South Carolina, references Warren Buffet. Buffet, the chairman of Berkshire Hathaway, is a legendary stock trader. He is not believed to have any tie to PPE. The reference to Buffet as a "game changer" -- and images of a bull and a bear -- may make it harder for PPE to argue it is not selling securities as the South Carolina litigation proceeds. A PPE prospect or prosecutor reasonably could ask, "If PPE is not selling an investment, why does a video promo reference Warren Buffet and include images of a bull and bear?" Images of bulls and bears are inexorably linked to the investment business

While securities regulators in South Carolina say a murky business known as PPE-Life recently has been holding recruitment meetings in the state, web records suggest that online recruitment efforts actually got under way months ago in anticipation of the company’s launch.

Efforts to promote PPE appear to have begun in January, at least three months prior to PPE’s corporate registration being recorded in Florida and despite the fact virtually nothing was known about the firm’s business practices and business mix.

At the same time, some promoters of PPE-Life appear to be building downlines by using a video that features narration about celebrated investment strategist Warren Buffet. The video is potentially embarrassing — if not problematic — for PPE because the company is facing a challenge in South Carolina amid allegations it is selling unregistered securities.

Because Buffet — who is not believed to have any tie to PPE — is one of the foremost investment experts in the world, prospects and prosecutors alike reasonably could ask why his name is referenced in promotions for PPE if the company is not in the securities business. They also could ask why his name is referenced at all if Buffet has no tie to PPE.

On Tuesday, the office of South Carolina Attorney General Henry McMaster described PPE-Life as a Florida company reluctant to provide details about its business, including the name of an unspecified “international bank” with which it purportedly is affiliated. McMaster ordered the company to cease and desist from selling securities and collecting money in the state.

Advertisements and web records dating back to January, however, described PPE-Life as the “marketing arm” of an entity known as “PPE Bank International.” No such entity appears to have been registered in Florida, although a corporation named “PPE-Life Inc.” was formally registered on April 29, about three months after recruitment ads referencing both PPE-Life and PPE Bank International began to appear online.

Other online references to PPE describe it as an “Agent with an offshore Lending Institution.”

When John Barter, a PPE officer, was asked at a May 20 recruitment meeting in Sumter, S.C., to identify the bank, Barter allegedly responded that “I am the bank.”

“Barter did not identify any bank and provided no evidence any such bank existed, but instead asserted, ‘I am the bank,'” according to South Carolina securities regulators.

A domain name — PPELife.com — also was registered in January. The domain redirects to a website that displays a video. A message that reads “PPE Marketing welcomes you!” appears in the upper-right corner of the website, and the video includes images and commentary about NBA legend Michael Jordan and Microsoft Chairman Bill Gates, along with an image of a bull and a bear and narration about Berkshire Hathaway Chairman Warren Buffet.

“Warren Buffet didn’t invent the stock market,” the video’s narrator intoned. “He changed the game of investing.” Gates was described as having changed the game of technology, and Jordan was described as having changed the game of basketball.

It is not believed that Buffet, Gates and Jordan have any tie to PPE.

It is common for multilevel-marketing (MLM) companies and affiliates to use images of celebrities and captains of industry in web promotions — even if the individuals depicted in photographs and mentioned by narrators have no connection to the business opportunities being advertised.

The video appears to be a recruitment video to help participants build downlines in PPE and other programs. Although PPE’s name is not mentioned in the video, it is possible that the references to Buffet and Gates could put PPE in the position of explaining why promoters are spotligting the names of individuals associated with publicly traded companies if PPE is not in the business of selling securities. Meanwhile, the images of bulls and bears are inexorably tied to investment opportunities.

Elsewhere on the web, a free classified ad with a publication date of Jan. 24, 2010, says this:

“Ppe life is the marketing arm of ppe bank international. as a result of this marriage, banking has gone mlm!”

The ad further claimed that PPE had chosen a service-provider for a recruitment feeder system.

“what does this mean to you?” the ad asked. “this means that you can receive a paid position in this ground floor global opportunity for only $66 (one-time) not $599 (one-time). for $66 one- time, you will join a group of experienced entrepreneurs in a simple, forced 2×2, three-phase feeder system that will generate a third phase payout of $1,840. $599 of your $1840 will be used to to pay for your independent associate membership in ppe life. as an independent associate of ppe life you will receive: *a mastercard or visa credit card with a $1,000 limit (without a credit check)… *a monthly subscription to ppe lif …”

The final words of the ad appear to have been cut off.

Web records suggest that PPE affiliates are using at least two different feeder companies to build downlines in PPE. The presence of the feeder system suggests PPE’s recruitment efforts may be more widespread than initially believed, crossing both domestic and international borders.

McMaster’s office said Tuesday that people who attended a May 20 PPE sit-down meeting in South Carolina were asked to pay $599 as an “initial membership fee” and a $50 per month “maintenance fee” thereafter. Attendees further were advised that returns of “up to $440,000 per year” could be earned through PPE.

Attendees also were told they’d become eligible for loans at a “significant discount” and that funds collected from participants would be used to purchase “debentures earning 40% to 50% interest.”

People who signed up were told they could earn “1.5% of loan payments on loans made to any members who subsequently join[ed] PPE” and also would receive a “free” credit card with a $1,000 limit, authorities said.