| FCS Comments: | CAREIF’s Response: |
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| Not Licensed or Registered to Sell Securities. | THAT’S TRUE, this is a Statement of Fact: Given that we are a Real Estate based company, our research indicates that our products are not securities, therefore we are NOT required by Jamaican law to be registered with the FSC. FSC regulates Insurance, Securities & Pension Funds, NOT REAL ESTATE. We hold it to be true that we operate outside of the FSC’s jurisdiction. |
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| Paying High Monthly Returns. | NOT TRUE; We DO NOT make monthly payments; we profit share every three years based on ownership in our developments. |
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| Do Not Provide Financial Statements (Audited or Unaudited). | NOT TRUE; We have provided financials to our RIC Members at our May 2007 AGM. Joint Venture Equity partners can get financials at request. With Real Estate investments and development projects, preparing quarterly audited statements does not apply based on the nature of the activities involved. |
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| We refuse to disclose to investors what we own or how much we owe | NOT TRUE; We give full disclosure on our projects. Our contracts indicate property involved, cost, projected profit etc. RIC members are NOT investors but ARE provided with financials and company overview at AGM. |
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| Do Not provide prospectus or information memorandum giving comprehensive and verifiable details. | NOT TRUE; details can be found on our website. Our detailed prospectus is available to partners and members online in their back office login. Interested persons can also access these information at a cost (we want people who are seriously interested to have access to such details). |
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| RIC membership agreement is an investment contract and should be registered. | NOT TRUE; RIC is not an investment instrument; it is a membership organization where our members get discounts and special benefits on our services and products. RIC is a consumer club and is not regulated. There are many consumer clubs in Jamaica as well as others such as Sam’s or BJ’s in the USA. FSC RELIES HEAVILY ON USING US law. |
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| We are trading high risk investment. | NOT TRUE; We are not high risk; All investments are backed by Real Estate. We don’t take mortgages that will dilute profitability or risk the property. We don’t pay interest to add to our debt burden. IT IS A FACT THAT Real estate has always outperformed all other types of investment. All our Joint Venture Equity partners are owners of the development. |
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| Avoiding the Scrutiny of the regulatory bodies. | NOT TRUE; FSC does not regulate Real Estate. We are already regulated by the laws of Jamaica: the Companies Act, the Real Estate Act and the Real Estate Board. In fact before we open our doors in 2005 we sent our prospectus and documents to the FSC for scrutiny and advice. We (including our Lawyers) have met with the FSC on numerous occasions to dispel any thoughts of us operating a “dubious investment Schemes.” So far we have made necessary adjustments to our contracts according to FSC’s concerns. |
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| Disclaimer: We have no problems being regulated, as soon as the FSC finds a suitable category/classification under which we can be justly regulated. We do all our transactions through the banks therefore our transactions can be traced. To this date FSC cannot provide us with any JAMAICAN Law requiring CAREIF’s real estate investments to be registered as a security. While we may use terms such as Investments, Equity, Interest & Returns, they refer specifically to our REAL ESTATE INVESTMENTS AND DEVELOPMENTS. We are providing every Jamaican with the opportunity to access the real estate market and the wealth building opportunity it provides. The FACT that the FSC has named CAREIF in a list of alternative investment schemes is irresponsible on their part, especially where the claims made does not fit or describe the operations of CAREIF in any way. Who stands to gain from destroying a legitimate company that seeks to solve pressing social problems and distribute wealth to the ordinary Jamaican? |
