The first predicate act was creating a retention bonus to
defraud the government and hide the payments, the second and beyond were
updating Envision plans for accounts governed by the Advisors Act without
including the fees charged.
The first predicate act was signing false certifications, the second
was misleading shareholders, Wachovia's board and a North Carolina business court during the
merger, and the third was Robert Steel become president of Perrella Wienberg.