investors were able to buy and sell Prosper loans ("notes") at any time. However, Prosper declared in its prospective dated December 21, 2016, that its relationship with Folio Investing had terminated on October 31, 2016. Consequently, note purchasers were informed that they would have to hold their notes to maturity unless Prosper were to establish a new secondary market platform, for which it made no assurance. Wells Fargo appears as a trustee in Prospers note indenture. IRA investor accounts As of March 1, 2012, Prosper allows tax-free or tax-deferred investment via self-directed IRA accounts. Traditional IRAs, Roth IRAs, SEP IRAs, and 401(k) Rollovers are supported through Prosper's IRA custodian partners Equity Institutional and Millennium Trust. The minimum investment required to open a self-directed Prosper IRA account is $5,000. Cease and desist order On November 24, 2008, the SEC found Prosper to be in violation of the Securities Act of 1933. As a result of these findings, the SEC imposed a cease and desist order on Prosper. Due primarily to the novel nature of the peer-to-peer lending models, the SEC, after review, now treats all peer-to-peer lending transactions as sales of securities and requires that all platforms register with the SEC. Litigation On November 26, 2008, a class action lawsuit was filed against Prosper in the Superior Court of California, County of San Francisco, California. The suit was brought on behalf of all loan note purchasers in Prosper's online lending platform from January 1, 2006 through October 14, 2008 and alleges that Prosper offered and sold unqualified and unregistered securities in violation of the California and federal securities laws. The lawsuit seeks class certification, damages, the right of rescission and the award of attorneys’ fees. Prosper's insurer, Greenwich Insurance Company, refused to pay for defense expenses, claiming the matters involved were not covered by the insurance policy. On December 14, 2010, Judge Richard A. Kramer of California Superior Court issued a tentative decision ruling for Prosper on this limited issue and holding that Greenwich is obligated to defend Prosper in the class-action suit and to reimburse Prosper's litigation expenses so far. Although the decision did not rule on the lawsuit itself or address whether Prosper might be entitled to insurance coverage in the event any of the lawsuit's claims proved meritorious, it relieved Prosper of significant legal expenses in the interim. The lawsuit was settled July 19, 2013 for 10 million