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Ethics Board Docket No. 2025-171 <br /> Page 4 of14 <br /> essentially outsourced the investment of the funds it received through the CEA to Chromos, and <br /> Chromos received a fee based on the funds managed. <br /> 7. <br /> In 2022, Mr. Adams approached Mr. Berthelot about receiving a short-term bridge loan. <br /> On Apri128, 2023, Chromos loaned Mr. and Mrs. Adams the sum of$780,000, as evidenced by a <br /> promissory note executed by Mr. and Mrs. Adams (the "Adams-Chromos Loan"). The Adams- <br /> Chromos Loan had an annual interest rate of 2.60%, with no fixed repayment term. Mr. and Mrs. <br /> Adams executed a collateral mortgage in favor of Chromos in which Mr. and Mrs. Adams offered <br /> investment retirement accounts as collateral in connection with the Adams-Chromos Loan. No <br /> security device evidencing the collateral was publicly recorded. Mr. and Mrs. Adams did not pay <br /> any closing costs in connection with the Adam-Chromos Loan. <br /> 8. <br /> The funds Chromos used to provide Mr. Adams with $780,000 were the direct result of a <br /> loan from LORA to Chromos. LORA withdrew$780,000 from its checking account on April 14, <br /> 2023. Chromos deposited$780,000 in its checking account on April 14, 2023. On April 28, 2023, <br /> LORA loaned Chromos the sum of$780,000, as evidenced by a promissory note executed by Mr. <br /> Berthelot(the"Chromos-LORA Loan"). The Chromos-LORA Loan had an annual interest rate of <br /> 2.80%with a five-year term.No security device evidencing any collateral for the Chromos-LORA <br /> was publicly recorded. <br /> 9. <br /> Mr. Adams repaid the Adams-Chromos Loan in full in October 2023 after obtaining <br /> permanent financing secured by a mortgage on immovable property. $200,000 was paid to <br />