SEC Charges Goldman Small Cap Research and its Owner for Failing to Disclose Compensation

On June 30, the Securities and Exchange Commission (the “SEC”) announced settled charges against Reuben Robert Goldman and his online stock promotion firm, Two Triangle Consulting Group LLC, which does business under the name Goldman Small Cap Research, for failing to disclose that they had been paid to create and distribute tweets promoting the securities of ten issuers.

Goldman, age 52, the founder, owner, and sole employee and “chief analyst” of Goldman Small Cap Research, is a resident of Pikesville, Maryland. Between 1989 and 2003, Goldman was associated with several broker-dealers and held Series 7, 62, 63, and 65 licenses.

Goldman Small Cap Research’s business primarily consists of producing promotional materials about microcap issuers and distributing these materials online to potential investors in exchange for cash payments from the issuers or third parties. Goldman Small Cap Research distributes stock market research and promotional material through its website (, subscription-based e-mail lists, and its accounts on Twitter and Facebook.

According to the SEC’s order, from April 2016 until March 2021, Goldman and Goldman Small Cap Research failed to disclose that they had been compensated by issuers for twenty-nine promotional tweets that they published through Goldman Small Cap Research’s Twitter account, @GoldmanSmallCap.

Each of the twenty-nine tweets included positive messages about the issuer’s business or commentary on the potential value of the issuer’s securities. In each of the tweets, Goldman included a “cashtag”—the issuer’s ticker symbol preceded by a dollar sign (“$”).

According to the order, Goldman and Goldman Small Cap Research were paid $39,931 to promote the securities identified in the tweets.

The SEC’s order finds that Goldman and Goldman Small Cap Research violated the anti-touting provision of Section 17(b) of the Securities Act of 1933.

The SEC’s order requires Goldman and Goldman Small Cap Research to cease and desist from committing or causing any violations or future violations of this provision, to comply with certain compliance-related undertakings, and to pay disgorgement of $39,931, prejudgment interest of $3,720.82, and a civil penalty of $39,931.

Goldman and Goldman Small Cap Research consented to the entry of the order without admitting or denying the SEC’s findings.


For further information about this securities law blog post, please contact Brenda Hamilton, Securities Attorney at 101 Plaza Real S, Suite 202 N, Boca Raton, Florida, (561) 416-8956, by email [email protected] or visit  This securities law blog post is provided as a general informational service to clients and friends of Hamilton & Associates Law Group and should not be construed as, and does not constitute legal advice on any specific matter, nor does this message create an attorney-client relationship.  Please note that the prior results discussed herein do not guarantee similar outcomes.

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