Eagle Training Portal
Compliance
CIM-verified guidelines for all investor communications. Violations are grounds for immediate termination.
Critical: Liability & Disclosure
As a representative of a Joint Venture, you carry significant responsibility. This is not a security sale; it's the formation of a general partnership. Failure to disclose material facts, especially regarding liability and legal history, can expose you and the company to severe legal and financial consequences. Adherence to these CIM-verified rules is not optional.
Prohibited vs. Approved Language
| Never Say This | Say This Instead (CIM-Compliant) |
|---|---|
| "Guaranteed returns" | "Projected/targeted/estimated returns based on engineering reports" |
| "This is a safe/risk-free investment" | "All oil and gas investments have risks, including loss of capital. We mitigate risk through diversification and proven assets." |
| "You'll get your money back in 2 years" | "Payout timelines are estimates; actual cash flow depends on oil prices and production." |
| "This is a security" | "This is a Texas Joint Venture, a general partnership. You are a partner in the business." |
| "The tax deduction is a loophole" | "The tax benefits are explicitly defined in the Internal Revenue Code under sections 263(c) and 613A(c)." |
| "Don't worry about the legal docs" | "You must review the Confidential Information Memorandum (CIM) and all 5 closing documents before committing." |
Mandatory Disclosures & Procedures
Structure: Texas Joint Venture
Investors are general partners in a Texas Joint Venture under the TBOC. While ENR seeks exempt qualification, this is NOT a security. This structure comes with unlimited joint and several liability, which must be disclosed on every call.
Accredited Investor Verification
You must verify accredited investor status via bank/brokerage statements, W-2s/K-1s, or a letter from a CPA, attorney, or broker. The criteria are a $1M+ net worth (excluding primary residence) OR $200K+ individual / $300K+ joint income.
Legal & Financial Advice Disclaimer
State explicitly on every call: "I am not a CPA, tax advisor, or attorney." All investors must be advised to consult their own independent professionals. Your role is to provide information consistent with the CIM, not to give advice.
Closing Process
Closing requires 5 documents: Application Agreement, Questionnaire, Execution Page/POA, Ballot, and Rep Questionnaire. Wires go to a segregated account named "Pecos Valley Joint Venture". ENR has 30 days to accept or reject any application.
Prohibited Jurisdictions
No sales activities of any kind are permitted with residents of Alabama. This is a strict non-negotiable rule.
Legal Disclosures
All representatives must be aware of and prepared to discuss: the 2011 Alabama cease and desist order, Jeremy Paul's misdemeanor charges (2020, 2023), and the Pratap v. ENR lawsuit filed in August 2025. Transparency is mandatory.
CIM is the Source of Truth
The Confidential Information Memorandum (CIM) is the sole source of approved facts and figures. All statements, emails, and conversations must be 100% consistent with the CIM. The CIM must be provided to a prospect before they commit capital.
1031 Exchanges
1031 exchanges from real estate into oil and gas are permitted. This requires a separate agreement and the use of a Qualified Intermediary (QI). Do not advise on the process, but confirm it is an option available to the investor.
Pre-Call Compliance Checklist
Confirm These Before Every Investor Call