Sethi and his firms spent more than 90 per cent of the

administrative fees collected from investors despite their promise to return this money to investors if their visa applications are denied, while over USD 2.5 million of these funds were directed to Sethi's personal bank account in Hong Kong, SEC said. "Sethi orchestrated an elaborate scheme and exploited these investors' dream of earning legal US residence along with a positive return on their investment in a project that was not nearly the done deal that he portrayed," SEC said. Accusing Sethi of submitting false claims about the project, SEC said that such documents provided by him to the relevant agencies included a comfort letter from Hyatt Hotels and a backup financing letter from Qatar Investment Authority. SEC has further said that Sethi and his companies made a number of misrepresentations about the project to dupe investors and the marketing materials of the project claimed participation of three major hotel chains in the project: Hyatt, Intercontinental Hotel Group, and Starwood Hotels. "However, none of these hotel chains have executed franchise agreements to include a brand hotel in this project as represented to investors in the offering materials. "Two of the chains actually terminated prior deals with other Sethi-related entities more than two years before these offering materials were circulated to investors," SEC said.