If you have ever looked through SEC filings on EDGAR, you know most of it is dry, structured, and painfully consistent. That is why a Form D where multiple people’s middle names appear to have been changed to “Ryan” jumps off the page. It is not “proof” of anything on its own, I’m sure co-founder of Revolutionary Clinics, Gregory Ryan Ansin would agree. But it is absolutely the kind of anomaly that warrants a closer look. C D Services of America, LLC sat “above” Revolutionary Clinics (at least the entity called Revolutionary Clinics II, Inc.) as an ownership and financing vehicle. When Revolutionary Clinics went into financial distress and litigation (recent reporting): reporting on the receivership and lawsuits describes Revolutionary Clinics and affiliates including Revolutionary Growers and C D Services of America as being involved together in debt, lender actions, or rent disputes.


First, what is SEC Form D?
Form D is a notice filing, not a full registration statement. Companies use it to notify the SEC that they sold securities without registering the offering, typically relying on an exemption under Regulation D (Rule 504 or Rule 506) or certain statutory exemptions.
Form D filings are made electronically on the SEC’s EDGAR system, and after filing, they become publicly available.

Investor.gov describes Form D as a “brief notice” that typically includes identifying details like the names and addresses of key people associated with the issuer, plus basic information about the offering. investor.gov
Why “all middle names changed to Ryan” is unusual
In a normal Form D, names are not a creative writing exercise. They are identifiers. When you see a pattern like many middle names being replaced with the same word, it raises practical questions such as:
- Data integrity: Was the filing prepared carelessly, with auto fill, copy paste, or template errors?
- Internal governance: Who reviewed the filing before submission, and what controls failed?
- Identity clarity: If names are altered or inconsistent, it becomes harder for investors, regulators, journalists, or counterparties to accurately match individuals across filings and records.
There are innocent explanations (sloppy drafting, formatting bugs, or a misguided “joke” that made it into a legal filing). There are also more concerning explanations (attempts to confuse, obscure, or mislead). A single filing does not let you conclude motive, but it does justify scrutiny.
Why Form D details matter even though it is “exempt”
A Regulation D offering is exempt from registration requirements, but it is not exempt from antifraud provisions and other federal securities law obligations. DART
Also, Form D is not a casual upload. Federal rules require that a Form D be filed on EDGAR, and it must be signed by a person duly authorized by the issuer. eCFR+1
That is why obvious inconsistencies in identity fields matter. They are part of the public record and tied to an authorized signature.
If you spot something like this, what can you do?
If your goal is to document and escalate responsibly (without overstating what the anomaly “means”), here is a clean approach:
- Pull the filing directly from EDGAR and save a copy.
- Check for amendments and compare name fields across versions (sometimes errors get corrected, sometimes they persist).
- Cross reference the names against other filings, corporate registries, or court records to see whether it is an isolated mistake or a repeated pattern.
- Preserve your evidence trail: note the filing date, accession number, and screenshots of the relevant fields.
- Report concerns if appropriate: the SEC provides a portal to submit a tip or complaint (including possible securities law violations).
If you are submitting as a whistleblower seeking eligibility under the SEC Whistleblower Program, the SEC outlines how to submit through its TCR process.
Bottom line
A Form D is supposed to be a straightforward compliance notice. When it contains a bizarre, repeated naming alteration like “everyone’s middle name is Ryan,” it is a signal. Not a verdict, a signal. It tells you the filing deserves verification, comparison, and careful documentation, because public records are only useful if they are accurate.
Side by side comparison across C D Services of AMERICA filings
2016-09-01 (Form D)
- Securities offered: Equity
- Total offering amount: Indefinite
- Total sold: $5,600,000
- Investors: 40
- Sales commissions: $0
- Payments to execs, directors, promoters (use of proceeds): $250,000
2016-10-17 (Form D)
- Securities offered: Equity
- Total offering amount: Indefinite
- Total sold: $0
- Investors: 0
- Sales commissions: $0
- Payments to execs, directors, promoters (use of proceeds): $250,000
2017-05-08 (Form D)
- Securities offered: Equity
- Total offering amount: $6,000,000
- Total sold: $575,000
- Investors: 6
- Sales commissions: $0
- Payments to execs, directors, promoters (use of proceeds): $250,000
2018-02-01 (Form D)
- Securities offered: Equity, Debt, Option/Warrant, plus “Other: Secured Convertible Debt”
- Total offering amount: $18,000,000
- Total sold: $925,000
- Investors: 0
- Sales commissions: $0
- Payments to execs, directors, promoters (use of proceeds): $360,000
2018-11-28 (Form D)
- Securities offered: Equity
- Total offering amount: $13,000,000
- Total sold: $11,575,000
- Investors: 36
- Sales commissions: $0
- Payments to execs, directors, promoters (use of proceeds): $0
2019-07-30 (Form D)
- Securities offered: Equity
- Total offering amount: $13,000,000
- Total sold: $8,759,600
- Investors: 23
- Sales commissions: $250,000
- Payments to execs, directors, promoters (use of proceeds): $250,000
These Form D filings read like multiple separate offerings over time, with shifting security structures, minimum investment thresholds, and reported use of proceeds, but the internal inconsistencies, especially the 2018 and 2019 $13M filings where ‘amount sold’ and commission related lines do not track chronologically, warrant reconciliation against the underlying offering documents.


