According to the Complaint, Integrated Wealth Strategies, LLC. ("IWS") is in the business of setting up Charitable LLC’s (“CLLC’s”) for people wishing to maximize tax benefits. This class action was filed against IWS and one individual Defendant.

The Complaint alleges that the promotional materials and recommendations provided by IWS and its agents were misleading because they induced investors to invest in Drive Planning LLC's Real Estate Acceleration Loan (REAL) program without properly disclosing the risks associated with this investment. The Complaint states that IWS and its agents, acting as sales agents for Drive Planning LLC, presented the REAL investments as low-risk with substantial real estate backing.

The Complaint further alleges that these Defendants failed to conduct adequate due diligence on Drive Planning LLC and the REAL program, and did not disclose that they were receiving commissions for selling these investments. Investors were allegedly urged to invest significant amounts, including retirement funds, based on these representations. The Complaint contends that, unbeknownst to the investors, Drive Planning LLC was operating a Ponzi scheme, using new investor funds to pay earlier investors.

The Complaint alleges that as a result of the Defendants’ wrongful acts and omissions, and the subsequent collapse of the Drive Planning LLC scheme, Plaintiff and the other Class members have suffered significant losses and damages.

The Plaintiffs filed an Amended Complaint on June 5, 2025.