The Securities and Exchange Commission enjoined Sand Hill Exchange, an unincorporated business, and Gerritt Hall and Elaine Ou, who both ran Sand Hill, from selling over-the-counter security-based swaps to retail clients. Under the Dodd-Frank Wall Street Reform and Consumer Protection Action, OTC security-based swaps may only be offered to highly sophisticated or financially capable persons or entities known as eligible contract participants. Mr. Hall and Ms. Ou effectively ran Sand Hill as a securities exchange, without required registration, beginning in February 2015 (thus any transaction on the exchange was effectively an OTC transaction). The exchange effectively offered binary options linked to liquidity events (e.g., mergers, initial public offerings and dissolutions) and to the value of private companies and their securities. Sand Hill accepted payments of deposits by customers in both US dollars and Bitcoin. In addition to ceasing the offer and sales of OTC security-based swaps to retail persons, the respondents agreed to pay a fine of US $20,000. Previously, Sand Hill refunded all deposits to users.