Yes the same grandson of Conrad Hilton, Bradley Hilton president of Legion Capital llc, offering 6% gains paying out monthly over 12 months and 8% paying monthly over 36 months.  Have you seen the information sheet for your tribe to see how this compares to your bankers or 401k options paying you. Free benchmarking available to help meet the DOL regulations.  No cost consultations with your tribes counsel. Call to book a time for discussion.