As a result of the SEC investigation, Passi was found to have violated Section 10(b) of the Securities Exchange Act of 1934, as amended (the "1934 Act"), and Rule 10b-5 thereunder. He was ordered to cease and desist from future violations of those provisions and suspended from association with any broker or other securities industry professional or any involvement with any penny stock offering, with the right to reapply after one year. Further, he was barred from holding any supervisory position with a broker/dealer, municipal securities dealer, transfer agent, or rating agency for a period of two years, with a right to reapply. Passi was ordered to pay a civil penalty of $250,000 to the SEC. He was also required to forfeit any right to an offset to any claims by third parties against Passi.