Commissioner Stops Illegal, Fraudulent and “Dirty” Securities Offering

Mar 18

Securities Commissioner Travis J. Iles entered an emergency cease and desist order against Larry Scott Rogers, from Montgomery and Conroe, Texas.  The order accuses him of illegally and fraudulently offering securities to Texans.

The order also names D&S Recruiting DBA Legacy Leads, a business purportedly controlled by Rogers.  D&S Recruiting allegedly generates leads, largely for life insurance firms.  They are allegedly offering debt instruments issued by the company, promising D&S Recruiting will pay lucrative profits over a short term.  For example, a principal investment of $25,000 will allegedly return between $30,000 and $32,500 in just 30 to 40 days.

The order also names Dirty Dick’s Products aka Dirty Richard’s Products, another business purportedly controlled by Rogers.  Dirty Dick’s Products was organized to sell subscription boxes of spice rubs, according to the order.  Rogers and Dirty Dick’s Products are allegedly offering a combination of debt and equity investments, with at least one investment paying 10% interest over a term of 12 months. 

Rogers, D&S Recruiting and Dirty Dick’s Products are not registered to offer the securities in Texas.  They are also failing to comply with important laws requiring the truthful disclosure of all material facts. 

“The disclosure provisions are a hallmark of public protection,” said Commissioner Iles.  “They ensure investors are provided with the information necessary to weigh the risks associated with investments.  Transparency ensures investors are able to make fully-informed investment and retirement decisions. The responsibility for these disclosures falls squarely on the shoulders of investment promoters.”

The parties are accused of concealing information material to the investment schemes.  For example, they are accused of concealing Rogers’ 2016 Chapter 7 Bankruptcy filing.  Similarly, they are accused of not disclosing lawsuits tied to the failure to repay debt, including a judgment in federal court in 2015 and another judgment in state court in 2018. 

According to the order, consumers have been complaining about prior subscription schemes managed by Rogers – including complaints they were repeatedly charged without authorization and never received purchased goods.  Rogers, D&S Recruiting, and Dirty Dick’s Products are allegedly not providing potential investors with any information relating to the complaints levied by prior clients. 

The parties have 30 days to challenge the order.

Contact:  Joe Rotunda, Director of Enforcement, at or 512-305-8392.