PAUL KELLY, Jr., Circuit Judge.
Background
Defendant-appellant Douglas Hauck was a licensed real estate agent in Colorado. Together with Daniel Hoover and Richard Jorgenson, the principals of an organization called RAM Marketing, Mr. Hauck began to utilize several "no-money-down" schemes to sell properties, including "coinvesting" with buyers who could not qualify for loans. Mr. Hauck supplied downpayment
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