he Court of Appeals held that a person is liable as a "seller" of a security if they were the proximate cause the securities sale. An Avco loan officer became involved with Dare to be Great, a program that was found to be a security. The loan officer made appearances at Dare meetings and encouraged those present to apply for a loan through Avco to pay for their participation in the program. The manager endorsed the Dare program as a good investment. It was Avco's negligent supervision of its employees actions, endorsing the Dare scheme and encouraging membership, that gave rise to the company's liability as a "seller" of securities.

Full case is also available at: http://www.mlmlegal.com/legal-cases/Davis_v_AvcoFinancialServices.php