A. The Defendant is an actual manager of C Co., Ltd. (hereinafter “C”) mainly engaged in the sale and purchase of non-performing loans and investment projects by financial institutions.

B. After establishing C, from November 2013, the Defendant used the price for acquisition of bonds from the pre-sale investors and the pre-sale investors prior to the successful bid of non-performing loans for the purchase and sale business of non-performing loans by financial institutions such as Korea Savings Bank and the City Bank, for the bid price for the non-performing loans or non-performing loans and the price for acquisition of bonds from the pre-sale investors after the successful bid of the non-performing loans, and the price for acquisition of bonds from the transferee of the non-performing loans is used for the cancellation of the pledge established in the POL of the non-performing loans or non-performing loans, although the financial institutions, etc. which leased the balance of the successful bid of the non-performing loans after the successful bid of the non-performing loans have been used for the purpose of cancelling the pledge established in the POL of the non-performing loans or non-performing loans, it was no longer used for redemption or settlement of dividends to other pre-sale investors of the non-performing loans, interest, office expenses and employee expenses, and the price for acquisition of bonds and pledgee.

C. As above, the Defendant was operating C in the way of “losting”, and even if the Defendant received money from investors for the purpose of purchase of non-performing loans due to restrictions such as subordinate special agreements, or preferential rights to dividends from a bank granting a pledge loan, etc., the Defendant agreed to do so.