If someone told my younger self that someday people would take photographs with their phones, I would have wondered where you would insert the film.^* Today, the question would be "What is film?" When I headed the Department of Corporations in the mid 1990s,^** I would have had a similar reaction to the notion that someday people would purchase securities on their phones (i.e., without actually calling a stockbroker).

Technology continues to advance and what was once the unimaginable is now the available. Recently, the California Department of Financial Protection & Innovation, the successor to the Department of Corporations, announced that it had issued desist and refrain orders against two business entities, Technipal Ltd. d/b/a Alluo and Star Network. According to the DFPI, these companies offered and sold securities in the form of crypto asset interest-bearing accounts on their websites and apps.

The DFPI also announced publication of a brochure for consumers concerning app scams. The brochure is based on an alert posted last month by the North American Securities Administrators Association (NASAA). The brochure highlights the following "red flags":

• An app guarantees high percentage returns on investments.
• An investing app has no ratings/reviews, or it has negative ratings/reviews.
• An app advertises investment opportunities as risk-free, low risk, or guaranteed.
• An investing app promotes itself as an opportunity to earn passive income or offers referral bonuses to get others involved.
• There is online discussion about the app causing investor losses or being an investment scam.

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*The first camera phone appeared in 2000. 
**The earliest smartphone apps appeared in 1994.