Skip to main content

Division of Securities Enforcement Actions

This page contains enforcement actions issued by the Washington Division of Securities. Explore detailed information about each case – including charges, orders, and more. Use the filter below to quickly navigate to actions from other years.

View Prior Years – Older Layout

Order Number Respondents Type of Order Act Date Entered
S-22-3468-25-FO01 Obvious Clothing Inc., Obvious Clothing LLC, Todd Kimball Final Order Securities Act 03/21/2025
Statutes & Rules: RCW 21.20.010, RCW 21.20.040, RCW 21.20.140

Penalties & Remedies:
  • Fine: $60,000
  • Investigative Costs: $10,000
  • Cease and Desist

Findings:
  • Between 2008 and 2021, Respondents raised over $3.7 million from at least twenty-three investors.
  • The Respondents sold unregistered investments in a clothing business and were not registered to sell investments.
  • The Respondents made multiple material misrepresentations to investors, including misrepresenting the profitability of the business, and misused investor funds.
S-24-3809-25-CO02 Network in Action Int’l, LLC; Christopher Scott Talley Consent Order Franchise Investment Protection Act 03/18/2025
Statutes & Rules: RCW 19.100.020, RCW 19.100.070, RCW 19.100.080, RCW 19.100.140, RCW 19.100.170

Penalties & Remedies:
  • Investigative costs: $4,468.75;
  • Cease and desist;
  • Franchise registration statement revoked;
  • Respondents will not seek registration with the Securities Division for at least five years;
  • Termination offer to franchisees

Findings:
  • From 2020 to 2024, Respondent Christopher Scott Talley offered Network in Action networking group franchises to Washington residents, including unregistered franchises.
  • From 2020 through 2024, eight Network in Action franchises were sold to Washington residents, totaling $119,000 in franchise fees.
  • From February 2020 through 2024, the Respondents employed an unregistered franchise broker to offer and sell Network in Action franchises.
  • The Respondents failed to disclose material information related to the investment in the Franchise Disclosure Documents, including costs and lawsuits.

The Respondents made misrepresentations in the Franchise Disclosure Documents, including financial performance and territory rights. 
S-24-3849-25-SC01 JJB Beauty Holdings Corp. (“JJB Beauty”) Statement of Charges Franchise Investment Protection Act 03/18/2025
Statutes & Rules: RCW 19.100.020, RCW 19.100.080, RCW 19.100.170

Penalties & Remedies:
  • Intent to Enter Order to Cease and Desist

Allegations:
  • JJB Beauty sold an unregistered beauty salon franchise.
  • JJB Beauty failed to provide the franchisee with a Franchise Disclosure Document.
  • JJB Beauty made a misrepresentation of material fact concerning the status of its application for trademark registration. 

The Respondent has a right to request a hearing on the Statement of Charges.  
S-22-3439-25-CO01 Vanguard Marketing Corporation; The Vanguard Group, Inc., Consent Order Securities Act 03/18/2025
Statutes & Rules: WAC 460-20C-150, RCW 21.20.100, RCW 21.20.040

Penalties & Remedies:
  • Cease and desist;
  • Agreed remediation payments to affected Washington investors

Findings:
  • Vanguard Marketing Corporation failed to have an adequate supervisory system to ensure that its agents sufficiently communicated the risk that investors holding securities in taxable accounts could potentially receive significant capital gains distributions and related tax obligations.
  • Vanguard Group, Inc., failed to disclose the potential for higher capital gains distributions from lowering the investment minimum of the Institutional TRFs was materially misleading to investors holding Investor TRFs in taxable accounts.
S-23-3688-25-FO01 Hollywood Cardroom; Shawn Weintraub Final Order Securities Act 03/18/2025
Statutes & Rules: RCW 21.20.010, RCW 21.20.040, RCW 21.20.140

Penalties & Remedies:
  • Fine: Hollywood Cardroom - $20,000; Weintraub - $20,000
  • Costs: $2,500
  • Cease and desist

Allegations:
  • In 2022, the Respondents sold $990,000 of unregistered LLC membership units to 3 Washington investors.
  • The Respondents failed to disclose material information related to the investment, such as the risks of investing and basic information about the company.
  • The Respondents sold unregistered investments in Hollywood Cardroom, and Weintraub was not registered to sell investments.

This resolves a previous Statement of Charges.  
S-23-3676-24-SC01 Doncaster Financial, Inc. Thomas Doncaster Statement of Charges Securities Act 03/14/2025
Statutes & Rules: RCW 21.20.020, RCW 21.20.100, RCW 21.20.350, WAC 460-24A-060, WAC 460-24A-200, WAC 460-24A-205, WAC 460-24A-220

Penalties & Remedies:
  • Cease and desist
  • Revoke registrations;
  • Deny future registrations
  • Fines & costs

Allegations:
  • The Respondents filed false or misleading balance sheets with the Securities Division.
  • The Respondents failed to material information regarding a business relationship with another investment adviser representative and failed to disclose a compensation agreement with that investment adviser representative.
  • The Respondents cause documents to be filed with the Securities Division that contained a statement that was false or misleading.
  • The Respondents failed to update their Form ADV Part 2.
  • The Respondents engaged in dishonest or unethical business practices, including engaging in nondisclosure, incomplete disclosure, and/or deceptive practices, and by failing to disclose to a material conflict of interest.

The Respondents have a right to request a hearing on the Statement of Charges.  
S-22-3451-25-FO01 Metallic Blue Development LLC; Brian Dozier Final Order Securities Act 02/21/2025
Statutes & Rules:

Penalties & Remedies:
  • Fine: $100,000
  • Cease and Desist

Findings:
  • Between 2019 and early 2022, Respondents raised over $40 million from over four hundred investors, including more than $3.5 million from approximately forty Washington investors.
  • The Respondents sold unregistered investments in individual real estate projects and real estate funds, and were not registered to sell investments.
  • The Respondents made untrue statements of material fact and failed to disclose material information related to the investments.

This resolves a previous Statement of Charges.
S-18-2481-24-FO01 RRIM Asset Strategies, LLC and Robert Alexander Ritter Final Order Securities Act 01/29/2025
Statutes & Rules: RCW 21.20.110

Penalties & Remedies:
  • Fine: $20,000
  • Investigative costs: $1,500
  • Deny future registrations

Findings:
  • Respondents falsely represented the Respondents’ principal place of business was in Washington, while actually operating  unlicensed in Arizona.  

The Respondents have a right to request judicial review of the Final Order.
S-23-3593-25-CO01 Chameleon Partners LLC Consent Order Securities Act 01/29/2025
Statutes & Rules: RCW 21.20.140

Penalties & Remedies:
  • Fine: $3,000
  • Investigative Costs: $5,000
  • Cease and desist

Findings:
  • In or around 2016, the Respondent offered and sold unregistered securities in the form of limited liability company membership interests to 43 investors
  • The Respondent did not take reasonable steps to verify its investors were accredited, so it did not satisfy the relevant exemption from registration. 
S-24-3828-24-SC01 Investment Design Management, LLC; Maximillian Morgan; Justin Sumner Statement of Charges Securities Act 01/15/2025
Statutes & Rules: RCW 21.20.040

Penalties & Remedies:

Intent to order: Cease and desist; Disgorge; Fines & costs


Allegations:
  • Between October 27, 2022, and April 23, 2023 and also from August 18, 2023 to the present, the Respondents provided investment advice and collected advisory fees, without proper registration as an investment adviser and investment adviser representative in Washington State.

The Respondents have a right to request a hearing on the Statement of Charges.