2020 Division of Securities Enforcement Actions

Orders From Other Years

2024 | 2023 | 2022 | 2021 | 2020 | 2019 | 2018 | 2017 | 2016 | 2015 | 2014 | 2013 | 2012 | 2011 | 2010 | 2009 | 2008 | 2007 | 2006 | 2005 | 2004 | 2003 | 2002 and Earlier

Cape Point Wealth & Tax Management, LLC and Michael Glick - S-20-2944-20-SC01 - Statement of Charges

On December 31, 2020, the Securities Division entered a Statement of Charges and Notice of Intent to Enter an Order to Revoke Registrations, Impose Fines, and Charge Costs (“Statement of Charges”) against respondents Cape Point Wealth & Tax Management, LLC (“Cape Point”, CRD #305344) and its owner Michael Glick (CRD #4798927). The Statement of Charges alleges that the respondents failed to file Cape Point’s annual updating amendment to its Form ADV and failed to timely file its year-end balance sheet. The Statement of Charges gives notice of the Securities Division’s intent to enter an order to revoke the investment adviser registration of Cape Point and the investment adviser representative registration of Michael Glick, to impose administrative fines, and to charge investigative costs. The respondents have a right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on April 1, 2021.

Gary Len Wells - S-20-2852-20-SC01 - Statement of Charges

On December 30, 2020, the Securities Division entered a Statement of Charges and Notice of Intent to Enter an Order to Cease and Desist, Deny Applications, Deny Future Registration, Impose a Fine, and Charge Costs (“Statement of Charges”) against Respondent Gary Len Wells (CRD #1142058).

In the Statement of Charges, the Securities Division alleges that Respondent, while working as a securities salesperson and investment adviser representative, engaged in unethical practices in violation of the Securities Act of Washington concerning two elderly clients. The Statement of Charges alleges that Respondent accepted a bequest of over $600,000 from one client’s estate in violation of firm policies after he was notified he could not accept the bequest. The Statement of Charges additionally alleges that, in regard to another client, Respondent (1) acted outside of the scope of his role as an investment adviser representative in violation of firm policies, including ongoing involvement with the client’s care and finances, and (2) recommended the conversion of the client’s account from a brokerage account to an asset-based account without a reasonable basis, resulting in a significant increase in fees. The Statement of Charges gives notice of the Securities Division’s intent to enter an order to deny Respondent’s pending investment adviser representative and securities salesperson applications; to deny any application of Respondent for registration with the Securities Division for five years; to order Respondent to cease and desist from violations of the Securities Act of Washington; to impose a fine of $100,000; and to charge costs of $1,000. The Respondent has the right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on January 1, 2022.

Michael Pace, CFP (CRD #113986) – S-20-3033-20-SC01 - Statement of Charges

On December 18, 2020, the Securities Division entered a Statement of Charges and Notice of Intent to Revoke Registration (Statement of Charges) against Respondent Michael Pace, CFP (Pace CFP). In the Statement of Charges, the Securities Division alleges that Pace CFP failed to maintain a compliant business continuity and succession plan as required of registered investment advisers. As a result, when the owner of Pace CFP died, Pace CFP did not have a complete set of books and records of the investment adviser nor any qualified person in place to carry out the investment adviser’s business. The Securities Division intends to revoke the investment adviser registration of Pace CFP. Pace CFP has the right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on March 03, 2021.

Hoover, Christopher - S-20-2880-20-SC01 - Statement of Charges

On November 13, 2020, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, Impose Fines, and Charge Costs (“Statement of Charges”) against Respondent Christopher Hoover (“Hoover”). In the Statement of Charges, the Securities Division alleges that Hoover made an unregistered offer of investments in medical devices, and misrepresented or failed to disclose material facts in connection with the offer. Hoover has the right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on June 15, 2021.

Magnuson Company, L.L.C. (d/b/a Magnuson Hotels, d/b/a Magnuson Worldwide) - S-20-2917-20-CO01 - Consent Order

On November 10, 2020, the Securities Division entered into a Consent Order with Magnuson Company, L.L.C. d/b/a Magnuson Hotels, d/b/a Magnuson Worldwide (Respondent). In the Consent Order, the Securities Division alleged that the Respondent violated the Franchise Investment Protection Act by offering and selling franchises while not registered to do so and by failing to provide franchisees with a franchise disclosure document. Without admitting or denying the Securities Division’s allegations, the Respondent agreed to cease and desist from violating the franchise registration and franchise disclosure document sections of the Franchise Investment Protection Act. The Respondent agreed to pay investigative costs of $2,500 and waived its right to a hearing and judicial review of the matter.

Brian Lockett – S-20-2882-20-CO01 - Consent Order

On November 10, 2020, the Securities Division entered into a Consent Order with Respondent Brian J. Lockett (Lockett) (CRD #4573162). This Consent Order stemmed from a Letter of Acceptance, Waiver, and Consent (AWC) agreed to by Lockett and the Financial Industry Regulatory Authority (FINRA) in November 2019, in which Lockett neither admitted nor denied the findings and agreed to be suspended for 45 days from acting as a registered representative for a broker-dealer and to pay a $5,000.00 fine. The Securities Division alleges in its Consent Order that Lockett violated the dishonest and unethical business practices and unlawful acts of a person advising another sections of the Securities Act of Washington and their associated regulations by participating in a $50,000.00 private securities transaction for a client without providing prior written notice to his broker-dealer, by attempting to conceal his role in this transaction from his broker-dealer, and by violating FINRA rules. Lockett was not compensated for participating in this transaction. In agreeing to the Consent Order, Lockett neither admitted nor denied the findings, and agreed to be suspended for a 45-day period from acting as an investment adviser representative, served retroactively to his FINRA suspension. Lockett also agreed to be subject to a heightened supervision plan by his sponsoring firms for the next two years, to pay a fine of $5,000.00, and to pay investigative costs of $2,550.00. Lockett waived his right to a hearing and to judicial review of the matter.

REACH Genetics Inc. f/k/a Doyen Elements Inc. – S-18-2482-20-FO01 - Final Order

On October 30, 2020, the Securities Division entered a Findings of Fact and Conclusions of Law and Final Order to Cease and Desist, to Impose a Fine, and to Charge Costs (Final Order) against REACH Genetics Inc. f/k/a Doyen Elements Inc. (Respondent). In the Final Order, the Securities Division concluded that Respondent violated the antifraud provision of the Securities Act of Washington by failing to disclose material information to investors in its Regulation A – Tier 2 offering. Respondent has the right to request judicial review of the Final Order.

American Equities, Inc. and Ross Miles - S-19-2702-20-CO01 - Consent Order

On October 29, 2020 the Securities Division entered into a Consent Order with American Equities, Inc. and Ross Miles (“Respondents”). The Securities Division alleged that the Respondents raised more than $20 million through the sale of unregistered securities in the form of promissory notes and limited liability company interests issued by various entities. The Securities Division alleged that Ross Miles acted as an unregistered broker-dealer or securities salesperson, and that the Respondents offered unregistered securities and violated the anti-fraud provisions of the Securities Act of Washington. In settling the matter, the Respondents neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act. The Consent Order requires the Respondents to pay investigative costs of $15,000. In addition, the Consent Order imposes a $100,000 fine against each Respondent, the payment of which is deferred until investors have been repaid in full. The Respondents waived their right to a hearing and judicial review of this matter.

Ringside Development Company d/b/a Bio-One - S-20-3007-20-CO01 - Consent Order

On October 29, 2020, the Securities Division entered into a Consent Order with Ringside Development Company d/b/a Bio-One (Respondent). In the Consent Order, the Securities Division alleged that the Respondent violated the Franchise Investment Protection Act by offering and selling a franchise in Washington, while not registered to do so. Without admitting or denying the Securities Division’s allegations, the Respondent agreed to cease and desist from the registration and franchise disclosure document portions of the Franchise Investment Protection Act. The Respondent agreed to pay investigative costs of $1,000 and waived its right to a hearing and judicial review of the matter.

911 Restoration Franchise Inc. - S-20-2971-20-CO01 - Consent Order

On October 27, 2020, the Securities Division entered into a Consent Order with 911 Restoration Franchise Inc. (Respondent). In the Consent Order, the Securities Division alleged that the Respondent violated the Franchise Investment Protection Act by failing to furnish to a prospective franchisee a copy of the franchisor’s current disclosure document. Without admitting or denying the Securities Division’s allegations, the Respondent agreed to cease and desist from violating the franchise disclosure document portion of the Franchise Investment Protection Act. The Respondent agreed to pay investigative costs of $2,000 and waived its right to a hearing and judicial review of the matter.

Yuri Prostov and Global Investment Management Inc. dba Global Investment Advisors - S-16-2088-20-FO01 - Final Order

On October 22, 2020, the Securities Division entered a Final Order to Cease and Desist, to Deny Future Registrations, to Impose a Fine, and to Charge Costs (Final Order) against Yuri Prostov (“Prostov,” CRD #5668876) and Global Investment Management Inc. dba Global Investment Advisors (“Global Investment Management,” CRD #144000). In the Final Order, the Securities Division concluded that Prostov and Global Investment Advisors violated the Securities Act of Washington by acting as an investment adviser and/or investment adviser representative while not so registered in the state of Washington. The Securities Division further concluded that Prostov and Global Investment Advisors violated the Securities Act of Washington by misrepresenting their advisory fee to a client. Prostov and Global Investment Management each have the right to request judicial review of the Final Order.

Viet-An Hoan Ly, TangleTrade Management, and Inception Capital Management - S-18-2423-20-SC01 - Statement of Charges

On October 20, 2020, the Securities Division issued a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Deny Future Registrations, to Impose Fines, and to Charge Costs (Statement of Charges) against Viet-An Hoan Ly, TangleTrade Management, LLC, and Inception Capital Management, LLC.

The Statement of Charges alleges that Viet-An Hoan Ly, TangleTrade Management, and Inception Capital Management engaged in multiple violations of the Securities Act of Washington: by acting as unregistered investment advisers; by improperly assessing performance fees; by failing to disclose a conflict of interest; by falsely representing the use of investor funds; by making misleading projections about the value of fund investments; and by misrepresenting the type of investment provided to certain fund investors. The Statement of Charges further alleges that Viet-An Hoan Ly misrepresented material information as he raised funds for Inception Beast Genprex, LLC, an unregistered investment vehicle.

The Securities Division intends to order that Viet-An Hoan Ly, TangleTrade Management, and Inception Capital Management cease and desist from violations of the Securities Act of Washington, that their future securities registrations with the Securities Divisions be denied, and that they be liable for fines and costs.

Viet-An Hoan Ly, TangleTrade Management, and Inception Capital Management each has a right to request a hearing on the Statement of Charges.

Sun Asset Management, Inc. and Kevin Liu - S-20-3011-20-TO01 - Summary Order

On October 15, 2020, the Securities Division entered Summary Order S-20-3011-20-TO01 (“Summary Order”), summarily suspending the investment adviser registration of Sun Asset Management, Inc. (CRD 140435) and the investment adviser representative registration of Kevin Liu (CRD 4394803). The Summary Order also gave notice of the intent to revoke the registrations, impose a fine, and charge costs. The Summary Order alleges that the respondents failed to make Sun Asset Management’s books and records available for examination by the Securities Division. Respondents have a right to judicial review of the matter.

A Final Order was entered regarding this matter on March 24, 2021.

Binkele, Robert; Estate Planning Team Inc.; Mariani, Michael; Prestige Investment Management LLC - S-18-2520-19-SC01 - Statement of Charges

On October 6, 2020, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, Impose Fines, and Charge Costs (“Statement of Charges”) against Respondents Robert Binkele (“Binkele”); Estate Planning Team Inc. (“EPT”); Michael Mariani (“Mariani”); and Prestige Investment Management LLC (“Prestige”) (collectively, “the Respondents”). In the Statement of Charges, the Securities Division alleges that the Respondents violated the Securities Act of Washington in the offer, sale, and administration of a Deferred Sales Trust investment to a Washington resident couple. Specifically, the Securities Division alleges that the Respondents violated the antifraud provisions of the Securities Act of Washington by managing and advising the trust for over four years without having issued a promissory note which serves as the only instrument giving the trust legal obligations to the Washington resident couple. The Securities Division further alleges that the Respondents violated the registration provisions of the Securities Act of Washington by offering and selling the Deferred Sales Trust package of services without being appropriately registered or exempt from registration. The Statement of Charges gives notice of the Securities Division’s intent to enter an order to cease and desist from violations of the Securities Act of Washington; to deny any application by Binkele for registration with the Securities Division for one year; of to impose a fine of $20,000 against Binkele and EPT; to impose a separate fine of $20,000 against Mariani and Prestige; and to charge investigative costs of $15,000 to the Respondents generally. The Respondents each have the right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on March 29, 2023.

Margarita Man HQ, LLC - S-20-2980-20-CO01 - Consent Order

On October 6, 2020, the Securities Division entered into a Consent Order with Margarita Man HQ, LLC (Respondent). In the Consent Order, the Securities Division alleged that the Respondent violated the Franchise Investment Protection Act by offering and selling franchises in Washington, while not registered to do so. Without admitting or denying the Securities Division’s allegations, the Respondent agreed to cease and desist from violating the registration and franchise disclosure document portions of the Franchise Investment Protection Act. The Respondent agreed to pay investigative costs of $1,000 and waived its right to a hearing and judicial review of the matter.

GDS, LLC - S-18-2496-20-SC01 - Statement of Charges

On October 2, 2020, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Impose Fines, and to Charge Costs (Statement of Charges) against Guardian Data Systems, LLC, Lance J. Ott, Brett B. Taylor, Richard D. Gilchrist (Respondents). The Statement of Charges alleges that Respondents violated the Securities Act of Washington when they offered and sold at least $1,225,000 of unregistered securities to eight investors. The Statement of Charges also alleges that Respondents violated the anti-fraud provision of the Securities Act by failing to disclose material information to these investors. The Securities Division intends to order Respondents to cease and desist from violating the Securities Act of Washington, to impose administrative fines, and to charge investigative costs. Respondents each have a right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on July 14, 2021.

Trademining – S-20-3000-20-TO01 - Summary Order

On September 30, 2020, the Securities Division entered a Summary Order to Cease and Desist and Notice of Intent to Impose a Fine and Charge Costs (“Summary Order”) against TradeMining, Inc,, a/k/a Trademining.io, and Devon T. Shigaki (“Respondents”). The Summary Order alleges that Respondents are violating the Securities Act of Washington (“the Act”) by generally soliciting investors to purchase unregistered securities in the form of licenses for the Infinity Trade Engine, which purportedly trades in cryptocurrency. Respondents are generally soliciting investors on social media, craigslist postings, and on the website https://trademining.io. The Order also alleges that Respondents are violating the Act by failing to disclose material information to investors, including Shigaki’s financial background, the background of the person managing the Trade Engine, and specifics regarding the Trade Engine. The Division finds that continued violations of the Securities Act of Washington constitute a threat to the investing public, and it enters the Summary Order to Cease and Desist immediately. The Summary Order also gives notice of the Division’s intent to impose a fine of $10,000 and charge costs of $750. Respondents have an opportunity for a hearing on this matter.

A Consent Order was entered regarding this matter on May 6, 2021.

Davis, Jonathan – S-18-2410-20-FO01 - Final Order

On September 30, 2020, the Securities Division entered a Final Order as to Respondent Jonathan Davis (“Davis”). The Securities Division had previously issued a Statement of Charges against Davis and another Respondent, Douglas Charles Anderson, in connection with the offer and sale of interests in a marijuana retail entity, Diego Pellicer Inc., and a related publicly traded company, Diego Pellicer Worldwide Inc. The Final Order requires Davis to cease and desist from violating the registration provisions of the Securities Act of Washington. Davis has the right to request judicial review of the Final Order.

Slim Chicken’s Development Company, LLC – S-20-2961-20-CO01 - Consent Order

On September 29, 2020, the Securities Division entered into a Consent Order with Slim Chicken’s Development Company, LLC (Respondent). In the Consent Order, the Securities Division alleged that the Respondent violated the Franchise Investment Protection Act by offering and selling franchises in Washington, while not registered to do so. Without admitting or denying the Securities Division’s allegations, the Respondent agreed to cease and desist from violating the Franchise Investment Protection Act. The Respondent agreed to pay investigative costs of $1,000 and waived its right to a hearing and judicial review of the matter.

Doncaster Financial, Inc. and Thomas Doncaster – S-19-2766-20-CO01 - Consent Order

On September 25, 2020, the Securities Division entered into Consent Order S-19-2766-20-CO01 with Doncaster Financial, Inc. (CRD 304844) and Thomas Doncaster (CRD 1926394) conditioning the investment adviser registration of Doncaster Financial. Respondents waived their rights to judicial review of the matter.

Gregory D. Mrachek, Blue Gold co LC – S-19-2694-20-FO01 - Final Order

On September 24, 2020, the Director of the Department of Financial Institutions entered a Final Decision and Order as to Blue Gold co LC (“Blue Gold”) and Gregory D. Mrachek (“Mrachek”) (the “Final Order”) against Blue Gold and its principal Gregory D. Mrachek (“Mrachek”) (collectively, the “respondents”). On September 5, 2019, the Securities Division (the “Division”) had entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Impose Fines, and to Charge Costs (the “Statement of Charges”) against Blue Gold and Mrachek based on an offering related to obtaining massive amounts of drinking water and transporting it to the Persian Gulf region. The Statement of Charges alleged that Blue Gold and Mrachek each violated the securities registration and anti-fraud sections of the Washington State Securities Act (the “Act”), and that Mrachek violated the Act’s securities salesperson registration section. Mrachek requested an administrative hearing on the Statement of Charges for himself and for Blue Gold. On December 18, 2019, the administrative law judge scheduled a prehearing conference for January 3, 2020 and issued a Notice of Prehearing Conference that advised Mrachek that his appearance at the prehearing conference was mandatory. Mrachek failed to appear at the prehearing conference. As a result, the administrative law judge issued an Order of Default against Mrachek and Blue Gold and dismissed their appeals. The Final Order orders the Respondents to cease and desist from violating the Act’s securities registration and anti-fraud sections, and orders Mrachek to cease and desist from violating the Act’s securities salesperson section. The Final Order also orders each respondent to pay a $10,000 fine and to reimburse the Securities Division $1,250 for investigative costs. The respondents may submit a Petition for Reconsideration to the Director. The respondents also may seek judicial review of the Final Order.

Unikrn Inc.; Unikrn Bermuda Ltd. - S-18-2441-20-CO01 - Consent Order

On September 24, 2020, the Securities Division entered into a Consent Order with Unikrn Inc. (“Unikrn”) and Unikrn Bermuda Ltd. (collectively, “the Respondents”). The Securities Division alleged that the Respondents violated the registration provisions of the Securities Act of Washington by (a) selling unregistered securities in the form of UnikoinGold digital assets, which purchasers would reasonably have expected to appreciate in value due to Unikrn’s efforts, and (b) selling these securities without being appropriately registered. In a related proceeding, Unikrn agreed to pay a total penalty of $6.1 million to the Securities and Exchange Commission (“SEC”), with the SEC creating a Fair Fund to compensate UnikoinGold purchasers. Without admitting or denying the Securities Division’s allegations, the Respondents agreed to pay investigative costs of $10,000 and waived their right to a hearing and judicial review of the matter. The Respondents further agreed to pay a fine to the Securities Division of $300,000, with the fine being deemed satisfied by the payment to the SEC in the related proceeding.

Pinnacle Lending LLC, Waln Team Funding LLC, Paul DeLette Waln Jr., Tamara Christine King - S-19-2811-20-CO02 - Consent Order

On September 24, 2020, the Securities Division entered into a Consent Order with Respondent Paul DeLette Waln Jr. (“Waln”). The Securities Division found that Respondents offered and sold $325,000 of investments in Pinnacle Lending to at least two investors and more than $100,000 of investments in Waln Team Funding to at least two investors. The Securities Division found that Waln offered and sold unregistered securities and violated the anti-fraud provision of the Securities Act of Washington by misrepresenting and by failing to disclose material information about the investments. Without admitting or denying the Securities Division’s findings, Waln agreed to cease and desist from violating the registration and anti-fraud provisions of the Securities Act and to pay investigative costs of $5,000. Waln waived his right to a hearing and judicial review of this matter.

Halcyon Apartments CC4R, LLC and Paul DeLette Waln Jr. - S-20-2881-20-CO01 - Consent Order

On September 24, 2020, the Securities Division entered into a Consent Order with Respondent Paul DeLette Waln Jr. (“Waln”). The Securities Division found that Waln offered and sold a total of $1.9 million worth of Halcyon LLC membership unit investments to more than 25 investors. The Securities Division also found that Waln offered and sold unregistered securities. Without admitting or denying the Securities Division’s Findings of Fact and Conclusions of Law, Waln agreed to cease and desist from violating the Securities Act and to pay $5,000 of investigative costs. Waln waived his right to a hearing and to judicial review of this matter.

Geoffrey Wescott James a.k.a. Geoff James or Geoff Wescott, d.b.a. Veritas International Limited, d.b.a. Veritas Incorporated, d.b.a. Veritas Capital Partners, d.b.a. Aquila LTD Malta, and Wescott Special Projects - S-18-2523-20-FO01 - Final Order

On September 24, 2020, the Securities Division entered a Final Order to Cease and Desist, to Impose a Fine, and to Charge Costs (Final Order) against Geoffrey Wescott James a.k.a. Geoff James or Geoff Wescott, d.b.a. Veritas International Limited, d.b.a. Veritas Incorporated, d.b.a. Veritas Capital Partners, d.b.a. Aquila LTD Malta, (Respondents). The Final Order alleges that the Respondents violated the Securities Act of Washington by offering and selling unregistered securities and investment of over $500,000 to a Washington resident in the form a profit sharing interest in a gold bullion import/export venture and misrepresenting or failing to disclose material facts in violation of RCW 21.20.140 and .010 respectively. The Final Order alleges that Respondent James sold securities when not registered as a broker or securities salesperson in violation of RCW 21.20.040. The Respondents are ordered to cease and desist from violating the Securities Act of Washington, to pay an administrative fine, and investigative costs. Respondents each have the right to judicial review of the Final Order.

South Beach Capital Management, LLC and Richard Thomas - S-20-2963-20-TO01 - Summary Order

On September 18, 2020, the Securities Division entered Summary Order S-20-2936-20-TO01 summarily suspending the investment adviser registration of South Beach Capital Management, LLC (CRD 153451) and the investment adviser representative registration of Richard Thomas (CRD 1070461) (“Summary Order”). The Summary Order also gave notice of the intent to revoke the registrations, impose fines, and charge costs. The Summary Order alleges that the respondents failed to file South Beach Capital Management’s year-end balance sheet and its annual updating amendment to its Form ADV. Respondents have a right to judicial review of the matter.

Global Marine Exploration Inc., Robert Henry (“Bobby”) Pritchett III, Ronald R. Alber - S-20-2872-20-FO01 - Final Order

On September 17, 2020 the Securities Division entered a Final Order against Respondents Global Marine Exploration Inc. (“GME”) and Robert Henry Pritchett III (“Pritchett”). GME, whose principal place of business is located in Sebastian, Florida, is in the business of salvaging and recovering treasure from shipwrecks.

The Final Order found that in January 2012, GME and Pritchett violated the registration provisions of the Securities Act of Washington by offering and selling $27,700 worth of unregistered GME stock to a Washington investor. The Final Order also found that GME and Pritchett violated the anti-fraud provision of the Securities Act by making untrue and misleading statements and by failing to disclose material information about the stock. The Final Order imposed a fine of $10,000 and costs of $1,500 against Pritchett. GME and Pritchett each have the right to request judicial review of the Final Order.

Robert O. Abbott III - S-19-2691-20-CO02 - Consent Order

On September 16, 2020, the Securities Division entered into a Consent Order with Robert O. Abbott III (Abbott). Abbott was the president of and registered as an investment adviser representative with Harvest Capital Advisors, Inc. The Consent Order alleged that Abbott violated the investment adviser antifraud provision of the Securities Act of Washington by receiving a substantial gift and borrowing money from a firm client. Abbott neither admitted nor denied the allegations, but agreed to cease and desist from violations of the investment adviser antifraud provision, to voluntarily not apply for any securities licenses in the future, and to pay a $2,000.00 fine. Abbott waived his right to a hearing and to judicial review of the matter.

Hannes, Ron; Hannes Financial Services, Inc. - S-20-2873-20-CO01 - Consent Order

On September 16, 2020, the Securities Division entered a Consent Order with Respondents Ronald Walter Hannes (“Hannes,” CRD #1462241), and his company Hannes Financial Services, Inc. (“HFS”). The Securities Division had previously entered a Statement of Charges against Hannes and HFS. In the Statement of Charges, the Securities Division alleges that Hannes and HFS violated the Securities Act of Washington by employing a scheme to defraud their clients by selling unregistered, fictitious investments, concealing these sales from their broker-dealer, and falsifying documents in response to the broker-dealer’s internal investigation. The Securities Division further alleged that Hannes and HFS defrauded at least nineteen clients of at least $2.9 million. In the Consent Order, without admitting or denying the Securities Division’s allegations, Hannes and HFS agreed that any future applications for registration with the Securities Division shall be denied. Hannes and HFS further agreed to pay a fine of $45,000 and investigative costs of $5,000, and waived their right to a hearing and to judicial review of this matter.

TSMB, Hills – S-18-2571-20-CO01 - Consent Order

On September 15, 2020, the Securities Division entered into a Consent Order with The Sound Mortgage Brokers, LLC, Rochester 1-8, LLC, and Bruce Phillip Hills, a/k/a Phil Hills (Respondents). The Securities Division had previously entered a Statement of Charges against Respondents, which alleged that Respondents violated the Securities Act of Washington when they offered and sold about $132,250 of unregistered securities to a Washington investor. The Statement of Charges also alleged that Respondents violated the anti-fraud provision of the Securities Act by failing to disclose material information to the investor. In the Consent Order, without admitting or denying the Securities Division’s allegations, Respondents agreed to cease and desist from violating the Securities Act of Washington. Respondents each waived their right to a hearing and judicial review of this matter.

Signal Capital Management LLC - S-19-2819-20-CO01 - Consent Order

On September 15, 2020, the Securities Division entered into a Consent Order with Signal Capital Management LLC (“Signal Capital”). The Securities Division found that Signal Capital had offered a $50,000 investment in Signal Capital to a non-accredited Washington investor. The Securities Division found that Signal Capital made a Rule 506, Regulation(c) filing with the United States Securities & Exchange Commission, but failed to make a notice filing with the Washington Securities Division. Signal Capital was ordered to cease and desist from violating the registration provision of the Washington Securities Act and required to pay a fine of $5,000. Signal Capital waived its right to an administrative hearing and judicial review of this matter.

Morgan Rothschild – S-20-2868-20-CO01 - Consent Order

On September 10, 2020, the Securities Division entered into a consent order, order number S-20-2868-20-CO01, with Respondent Morgan Rothschild.

This consent order resolved the Statement of Charges and Notice of Intent to Deny Franchise Broker Registration, order number S-20-2868-20-SC01, that the Securities Division issued against Morgan Rothschild on May 18, 2020.

The consent order provides that the Securities Division will deny the franchise broker registration application filed by Morgan Rothschild on February 7, 2020. As part of the consent order, Morgan Rothschild neither admitted, nor denied the Securities Division’s Findings of Fact and Conclusions of Law. Morgan Rothschild further waived his right to a hearing and judicial review of this matter.

REACH Genetics Inc. f/k/a Doyen Elements Inc. and Geoffrey Thompson – S-18-2484-20-SC01 - Statement of Charges

On September 10, 2020, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Impose a Fine, and to Charge Costs (Statement of Charges) against REACH Genetics Inc. f/k/a Doyen Elements Inc. and Geoffrey Thompson (Respondents). In the Statement of Charges, the Securities Division alleges that Respondents violated the anti-fraud provision of the Securities Act of Washington by failing to disclose material information to investors in its Regulation A – Tier 2 offering. Respondents each have the right to request a hearing on the Statement of Charges.

A Final Order as to Geoffrey Thompson was entered on February 12, 2021.

A Final Order was entered regarding this matter on October 30, 2020.

Beverly Hills Jewelry & Loans, Inc., Alan Bernard Slotnikow - S-20-2915-20-FO01 - Final Order

On September 2, 2020, the Securities Division entered a Final Order against Respondents, Beverly Hills Jewelry & Loans, Inc. (“Beverly Hills”) and Alan Bernard Slotnikow (“Slotnikow”). The Final Order found that during July and August 2019, the Respondents violated the registration provisions of the Securities Act of Washington by offering and selling a total of $30,000 worth of unregistered Beverly Hills stock to an elderly Washington investor through “cold calling.” The Final Order also found that Respondents violated the anti-fraud provision of the Securities Act by failing to disclose material information about the stock. The Final Order imposed a fine of $20,000 and charged costs of $5,000 against Slotnikow. Beverly Hills and Slotnikow each have the right to request judicial review of the Final Order.

Harbour Driving School, Inc. d.b.a. Defensive Driving School and John Coburn Fawcett, Jr. a.k.a. J.C. Fawcett - S-20-2834-20-CO01 - Consent Order

On September 1, 2020, the Securities Division entered into a Consent Order with Harbour Driving School, Inc. d.b.a. Defensive Driving School and John Coburn Fawcett, Jr. a.k.a. J.C. Fawcett (“Respondents”). The Securities Division had previously entered a Statement of Charges against the Respondents on May 1, 2020. The Securities Division alleged that the Respondents sold at least two franchises in the state and received $25,000 in payment for a license. The Securities Division alleged that the Respondents failed to register the offer and sale of a franchise with the Securities Division and failed to provide franchisees with a franchise disclosure document. Respondent agreed to cease and desist from violations of RCW 19.100.020 and RCW 19.100.080, the franchise registration and franchise disclosure document sections of the Franchise Investment Protection Act. The Respondents agreed to pay investigative costs of $2,300 and waived their right to a hearing and judicial review of the matter.

Yuri Prostov and Global Investment Management Inc. dba Global Investment Advisors - S-16-2088-20-SC01 - Statement of Charges

On August 31, 2020, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Deny Future Registrations, to Impose a Fine, and to Charge Costs (Statement of Charges) against Yuri Prostov (“Prostov,” CRD #5668876) and Global Investment Management Inc. dba Global Investment Advisors (“Global Investment Management,” CRD #144000). In the Statement of Charges, the Securities Division alleges that Prostov and Global Investment Advisors violated the Securities Act of Washington by acting as an investment adviser and/or investment adviser representative while not so registered in the state of Washington. The Securities Division further alleges that Prostov and Global Investment Advisors violated the Securities Act of Washington by misrepresenting their advisory fee to a client. Prostov and Global Investment Management each have the right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on October 22, 2020.

Svaram Group, Inc., Svaram Global, LLC, and Murali K. Kuppa - S-18-2565-20-SC01 - Statement of Charges

On August 31, 2020, the Securities Division entered a Statement of Charges and Notice of Intent to Issue an Order to Cease and Desist, Impose Fines, and Charge Costs against Svaram Group, Inc., Svaram Global, LLC, and Murali K. Kuppa (collectively “Respondents”). The Securities Division alleges that Svaram Group was a start-up private equity fund operating from the greater Seattle area. In 2017, Kuppa solicited two Washington residents to invest a total of $150,000 with him in the organization and formation stage of the fund, in return for equity positions in Svaram Group and Svaram Global. The Securities Division alleges that the Respondents violated the anti-fraud provision of the Securities Act of Washington. The Securities Division ordered the Respondents to cease and desist from violating the Securities Act of Washington, and gave notice of its intent to collect fines and charge costs. Respondents have a right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on April 5, 2021.

GoYOcoin, Inc. - S-18-2519-20-CO01 - Consent Order

On August 25, 2020, the Securities Division entered into a Consent Order with GoYOcoin, Inc. The Securities Division had previously entered a Statement of Charges and Notice of Intent to Issue an Order to Cease and Desist, Impose Fines, and Charge Costs against YOcoin Limited d/b/a YOcoin and GoYOcoin, Inc. (collectively “Respondents”). The Statement of Charges alleged that in 2016, GoYOcoin, Inc. offered and sold the “YOC” digital currency to at least four Washington residents. The residents invested over $5,000 in YOC, which was issued by YOcoin, an offshore company. The Securities Division alleged that the Respondents sold unregistered securities, acted as an unregistered broker-dealer, and violated the anti-fraud provision of the Securities Act of Washington. The Respondent GoYOcoin, Inc. neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act of Washington, and to pay a fine of $1,000. The Respondent waived their right to a hearing and to judicial review of the matter.

Jeffrey A. Mascio - S-17-2194-20-FO02 - Final Decision and Order

On August 24, 2020, the Director of the Department of Financial Institutions entered a Final Decision and Order (Final Decision) against the Respondent Jeffrey A. Mascio. The Final Decision found that the Respondent violated the suitability provision of the Securities Act of Washington. The Final Decision denied the Respondent’s future securities registrations and ordered the Respondent to pay a fine of $20,000 and investigative costs of $5,000. The Respondent has the right to file a petition for reconsideration or to request judicial review.

Halydean Corporation - S-19-2736-20-CO01 - Consent Order

On August 17, 2020, the Securities Division entered into a Consent Order with Halydean Corporation (Respondent). The Securities Division had previously entered a Statement of Charges against Respondent, which alleged that the Respondent violated the Securities Act of Washington when it offered and sold about $25,000 of unregistered stock to five investors. The Statement of Charges also alleged that the Respondent violated the anti-fraud provision of the Securities Act by failing to disclose material information to investors. In the Consent Order, without admitting or denying the Securities Division’s allegations, Respondent agreed to cease and desist from violating the Securities Act of Washington, to pay $10,000 in fines, and to pay $10,000 in investigative costs. Respondent waived its right to a hearing and judicial review of this matter.

Gregory Lone; Paramount Financial Advisors LLC – S-19-2639-20-FO01 - Final Order

On August 5, 2020, the Securities Division entered an Entry of Findings of Fact and Conclusions of Law Final Order and Final Order to Cease and Desist, Deny Future Registrations, Impose Fines, and Charge Costs against Respondents Gregory Lone (“Lone,” CRD #2347566, OIC #227770) and his company Paramount Financial Advisors LLC (“Paramount”). In the Final Order, the Securities Division alleges that Lone and Paramount violated the Securities Act of Washington by employing a Ponzi scheme to defraud clients of over a half-million dollars. The Securities Division alleges that Lone convinced seven clients, almost all of whom were in their eighties or nineties, to write checks to Paramount for investment purposes. Rather than investing the funds as promised, Lone diverted them for his personal use or to repay clients who had been defrauded earlier in the scheme. The Securities Division orders Lone and Paramount to cease and desist from violations of the Securities Act of Washington, denies any future applications for registration with the Securities Division, imposes a fine of $70,000, and charges investigative costs of $10,000. Lone and Paramount have the right to request judicial review of the Final Order.

Baker & Associates, LLC, David Baker - S-19-2645-20-SC01 - Statement of Charges

On July 23, 2020, the Securities Division entered a Statement of Charges against respondents Baker & Associates, LLC (CRD 305284) and David Baker (CRD 809683) (“Respondents”). The Securities Division alleges that Respondents violated the Securities Act of Washington by holding themselves out as an “IRA investment advisor,” a “financial advisor,” and a financial planner while not registered as an investment adviser or investment adviser representative in Washington. The Securities Division intends to order Respondents to cease and desist from violating the Securities Act of Washington, to impose an administrative fine, and to charge investigative costs. Respondents each have the right to request a hearing on the Statement of Charges.

Anderson, Douglas; Davis, Jonathan - S-18-2410-20-SC01 - Statement of Charges

On July 23, 2020, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, Impose Fines, and Charge Costs (“Statement of Charges”) against Respondents Douglas Anderson (“Anderson”) and Jonathan Davis (“Davis”). In the Statement of Charges, the Securities Division alleges that (a) Anderson and Davis violated the registration provisions of the Securities Act of Washington through the unregistered offer of investments, via Craigslist, in Diego Pellicer Inc. and/or Diego Pellicer Worldwide Inc.; and (b) that Anderson violated the antifraud provisions of the Securities Act of Washington by misrepresenting or failing to disclose material information in connection with the sale of interests in Diego Pellicer Worldwide, Inc. The Statement of Charges gives notice of the Securities Division’s intent to enter an order to cease and desist from violations of the Securities Act of Washington, to impose a fine of $10,000 against Anderson, and to charge investigative costs of $5,000 to Anderson. The Respondents each have the right to request a hearing on the Statement of Charges.

A Consent Order as to Douglas Anderson was entered on March 03, 2021.

A Final Order was entered regarding this matter on September 30, 2020.

Michael Dennis Jackson – S-17-2329-20-CO01 - Consent Order

On July 22, 2020, the Securities Division entered into a Consent Order with Michael D. Jackson. The Securities Division had previously entered a Statement of Charges against Jackson, which alleged that Jackson violated RCW 21.20.020 and RCW 21.20.035 when he advised a client to open a brokerage account for Jackson to manage away from Jackson’s firm. Jackson then allegedly engaged in speculative trading in the account, which lost all of its value. In the Consent Order, without admitting or denying the allegations, Jackson agreed to cease and desist from violations of the Securities Act of Washington, to have his securities license suspended for three years, to pay restitution of $10,000 to the client, and to pay $2,500 in investigative costs. Jackson waived his right to a hearing and judicial review of this matter.

Thompson, Denis / ARPWave LLC - S-20-2951-20-SC01 - Statement of Charges

On July 13, 2020, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, Impose Fines, and Charge Costs (“Statement of Charges”) against Respondents Denis Thompson (“Thompson”) and his company ARPWave LLC (“ARPWave”In the Statement of Charges, the Securities Division alleges that Thompson and ARPWave violated the registration provisions of the Securities Act of Washington through the unregistered offer of ARPWave investments via Craigslist. The Securities Division further alleges that Thompson and ARPWave violated the antifraud provisions of the Securities Act of Washington by failing to disclose a reasonable basis for the extremely high returns contained in their advertisement. The Respondents have the right to request a hearing on the Statement of Charges

A Consent Order was entered regarding this matter on April 29, 2021.

Eight USA, Inc., dba Matcha Café Maiko – S-19-2813-20-CO01 – Consent Order

On July 7, 2020, the Securities Division entered into a Consent Order with Eight USA, Inc., dba Matcha Café Maiko (“Eight USA”). In the Consent Order, the Securities Division alleged that Eight USA violated the Franchise Investment Protection Act of Washington by offering unregistered franchises to Washington residents. Without admitting or denying the Division’s allegations, Eight USA agreed to cease and desist from violating the Franchise Investment Protection Act, and to pay $750 towards the costs of the investigation. Eight USA waived its rights to a hearing and judicial review of this matter.

Thoroughbred National, LLC and Gregory Ferry - S-19-2742-19-CO01 - Consent Order

On June 26, 2020, the Securities Division entered into Consent Order number S-19-2742-19-CO01 with Thoroughbred National, LLC (CRD 289435) and Gregory Ferry (CRD 6864337) (“Respondents”).

The Securities Division previously entered a Summary Order to Suspend Registrations and Notice of Intent to Revoke Registrations, Impose a Fine, and Charge Costs against Respondents. The Summary Order alleged that that Respondents failed to make Thoroughbred National, LLC’s books and records available for examination by the Securities Division.

The Consent Order states that Thoroughbred National, LLC is withdrawing its investment adviser registration and may not apply for registration as an investment adviser or broker-dealer in the state of Washington for a period of two years. The Consent Order additionally states that Gregory Ferry is withdrawing his investment adviser representative registration and may not apply for registration as an investment adviser, broker-dealer, securities salesperson, or investment adviser representative in the state of Washington for a period of two years. The Consent Order additionally includes a $500 fine and a $200 payment of costs. Respondents waived their rights to a hearing and judicial review of this matter.

Roger Henry Tilton and Full_Tilton Ventures LLC - S-19-2774-20-CO01 - Consent Order

On June 25, 2020, the Securities Division entered into a Consent Order with Respondents, Roger Henry Tilton (“Tilton”) and Full_Tilton Ventures LLC. The Securities Division found that Tilton, a former registered securities salesperson and investment adviser representative, offered and sold at least $625,000 worth of unregistered investments to at least seven investors, including at least one Washington investor. The Securities Division concluded that Respondents violated the anti-fraud provision of the Securities Act of Washington by misrepresenting and omitting material information when offering and selling the investments. The Securities Division ordered the Respondents to cease and desist from violating the Securities Act and imposed a $5,000 fine and charged $2,500 in costs against Tilton. Tilton also repaid $25,000 to the Washington investor. Without admitting or denying the Findings of Fact and Conclusions of Law, the Respondents waived their right to a hearing and to judicial review of this matter.

PrimeFund, Inc. dba WealthFlex, Joseph John DiDomenico - S-17-2323-20-CO01 - Consent Order

On June 25, 2020, the Securities Division entered into a Consent Order with Joseph John DiDomenico and Primefund, Inc., dba WealthFlex (Respondents). The Securities Division had previously entered a Statement of Charges against Respondents, which alleged that Respondents violated the Securities Act of Washington when they offered and sold about $478,000 of unregistered securities to six investors. The Statement of Charges also alleged that Respondents violated the anti-fraud provision of the Securities Act by failing to disclose material information to investors. In the Consent Order, without admitting or denying the Securities Division’s allegations, Respondents agreed to cease and desist from violating the Securities Act of Washington, to pay $10,000 in fines, and to pay $7,500 in investigative costs. Respondents each waived their right to a hearing and judicial review of this matter.

Pinnacle Lending LLC, Waln Team Funding LLC, and Tamara Christine King - S-19-2811-20-CO01 - Consent Order

On June 9, 2020, the Securities Division entered into a Consent Order with Respondents Pinnacle Lending LLC, Waln Team Funding LLC, and Tamara Christine King. The Securities Division found that Respondents had offered and sold $325,000 of investments in Pinnacle Lending to at least two investors and more than $100,000 of investments in Waln Team Funding to at least two investors. The Securities Division found that the Respondents offered and sold unregistered securities and violated the anti-fraud provision of the Securities Act of Washington by misrepresenting and failing to disclose material information about the investments. Without admitting or denying the Securities Division’s findings, the Respondents agreed to cease and desist from violating the registration and anti-fraud provisions of the Securities Act. The Respondents each waived their right to a hearing and judicial review of this matter.

603 Financial, Inc. d.b.a. Goddard Financial Planning - S-20-2875-20-CO01 - Consent Order

On June 5, 2020, the Securities Division entered into a Consent Order with 603 Financial, Inc. d.b.a. Goddard Financial Planning (CRD 167976) (“Consent Order”). The Consent Order states that Respondent employed an unregistered investment adviser representative from on or about September 13, 2016 to February 19, 2020 in violation of RCW 21.20.040; failed to terminate the registration of another investment adviser representative in violation of RCW 21.20.080; and failed to enforce policies and procedures designed to prevent violations of the registration provisions of Chapter RCW 21.20. The Consent Order includes a $15,000 fine. Respondent waived its right to judicial review of the matter.

Lynette A. Johnson - S-19-2691-19-CO01 - Consent Order

On June 4, 2020, the Securities Division entered into a Consent Order with Lynette A. Johnson (Johnson). Johnson was registered as an investment adviser representative while employed at Harvest Capital Advisors, Inc. (Harvest Capital). The Consent Order alleged that between approximately 2016 and 2018, Johnson accepted gifts totaling $115,000 from an elderly client of Harvest Capital, including when the resident had diminished mental capacity. The Respondent neither admitted nor denied the allegations, but agreed to the denial of any future securities registration applications, and to pay a $2,500 fine. The Respondent waived her right to a hearing and to judicial review of the matter.

Richard O. Johnson II - S-17-2275-20-FO01 - Final Order

On June 2, 2020, the Director of the Washington State Department of Financial Institutions entered a Final Order against Richard O. Johnson II (Respondent). In the Final Order, the Securities Division found that Respondent violated RCW 21.20.040 when he held himself out as a “certified financial planner” while not registered as an investment adviser, or exempt from such registration in the State of Washington. The Final Order ordered Respondent to cease and desist from any further violations of RCW 21.20.040. The Final Order ordered that any future securities registration application of Respondent as an investment adviser, broker-dealer, investment adviser representative, or securities salesperson shall be denied. The Final Order ordered Respondent to pay a fine of $10,000 and to pay costs of $2,000. Respondent has the right to petition the superior court for judicial review of the Final Order.

Lone, Greg & Paramount Financial Advisors LLC - S-19-2639-20-SC01 - Statement of Charges

On June 1, 2020, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, Deny Future Registrations, Impose Fines, and Charge Costs (“Statement of Charges”) against Respondents Gregory Lone (“Lone,” CRD #2347566, OIC #227770) and his company Paramount Financial Advisors LLC (“Paramount”). In the Statement of Charges, the Securities Division alleges that Lone and Paramount violated the Securities Act of Washington by employing a Ponzi scheme to defraud clients of over a half-million dollars. The Securities Division alleges that Lone convinced seven clients, almost all of whom were in their eighties or nineties, to write checks to Paramount for investment purposes. Rather than investing the funds as promised, Lone diverted them for his personal use or to repay clients who had been defrauded earlier in the scheme. The Statement of Charges gives notice of the Securities Division’s intent to enter an order to cease and desist from violations of the Securities Act of Washington, to impose a fine of $70,000, to charge investigative costs of $10,000, and to deny any of Lone or Paramount’s future investment adviser representative or securities salesperson applications for registration. Lone and Paramount have the right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on August 5, 2020.

Huston 3D Money - S-19-2672-20-CO01 - Consent Order

On May 28, 2020, the Securities Division entered into a Consent Order with Respondents Jeffery Allen Huston (Huston), 3D Money, LLC, AEHK, LLC, Maplewood Offering, LLC, and Sunrise Capital, LLC (Respondents). The Securities Division alleged in its consent order that Respondents violated the Securities Act of Washington by offering and selling unregistered securities in the form of promissory notes to Washington residents. Respondents were unable to rely on their claimed exemption from registration because they used a bad actor in their offerings, sold their securities through general solicitation, and did not provide required financial disclosures to non-accredited investors. Respondents Huston and 3D Money, LLC also violated the Securities Act of Washington by not registering as a securities salesperson or broker-dealer in Washington while offering and selling these securities. Additionally, Respondents violated the antifraud provision of the Securities Act of Washington by failing to disclose to investors the bad actor’s previous consent order with the Securities Division and that there was a conflict of interest in the bad actor’s recommendation of the securities to investors due to the Respondents paying to attend and sponsor the bad actor’s seminars.

Without admitting or denying the Securities Division’s allegations, Respondents agreed to cease and desist from violations of RCW 21.20.140, the securities registration provision; RCW 21.20.040, securities salesperson and broker-dealer registration section; and RCW 21.20.010, the antifraud provision of the Securities Act of Washington. Respondents agreed to pay a total of $13,312.50 in fines and investigative costs and waived its right to a hearing and judicial review of the matter.

Lifestyle Publications - S-20-2867-20-CO01 - Consent Order

On May 21, 2020, the Securities Division entered into a consent order with Lifestyle Media Solutions, LLC.

The Securities Division alleged that Lifestyle Media Solutions violated the registration and disclosure document provisions of the Franchise Investment Protection Act of Washington, in connection with the company’s sale of two community magazine franchises in Washington.

Without admitting or denying the Securities Division’s allegations, Lifestyle Media Solutions agreed to cease and desist from violating the Franchise Investment Protection Act of Washington. Lifestyle Media Solutions further agreed to pay $2,000 in investigative costs and waived its right to a hearing and judicial review of the matter.

Skylette Team, Inc. - S-20-2884-20-CO01 - Consent Order

On May 21, 2020, the Securities Division entered into a consent order with Skylette Team, Inc.

The Securities Division alleged that Skylette Team offered and sold an ice cream franchise in Washington without being registered to do so, in violation of the Franchise Investment Protection Act’s registration provision.

Without admitting or denying the Securities Division’s allegations, Skylette Team agreed to cease and desist from violating the Franchise Investment Protection Act of Washington. Skylette Team further agreed to pay $500 in investigative costs and waived its right to a hearing and judicial review of the matter.

Taylor Forrester Moffitt a.k.a. Taylor Moffitt of Halydean - S-19-2736-20-FO01 - Final Order

On May 20, 2020, the Securities Division entered an Entry of Findings of Fact and Conclusions of Law and Final Order to Cease and Desist, to Impose Fines and to Charge Costs (“Final Order”) against Taylor Forrester Moffitt a.k.a. Taylor Moffitt of Halydean (Respondent). The Final Order alleges that Respondent violated the Securities Act of Washington by offering and selling unregistered Halydean stock to five investors, raising at least $24,500 and misrepresenting or failing to disclose material facts to investors in violation of RCW 21.20.140 and .010 respectively. The Final Order alleges that Respondent Moffitt sold securities when not registered as a broker or securities salesperson in violation of RCW 21.20.040. The Securities Division ordered Respondent to cease and desist from violating the Securities Act of Washington, imposed an administrative fine of $24,500, and charged investigative costs of $16,470.17. Respondent has the right to request judicial review of the Final Order.

Chicago Doughnut Franchise Company, LLC, d.b.a. The Dapper Doughnut, Brian Pappas and Jeff Pappas - S-18-2406-20-FO01 - Final Order

On May 6, 2020, the Securities Division entered a Final Order against Respondents Chicago Doughnut Franchise Company, LLC d.b.a. The Dapper Doughnut, Brian Pappas, and Jeff Pappas. The Securities Division alleged that the Respondents filed a false or misleading franchise application in violation of RCW 19.100.170, the violations section of the Franchise Investment Protection Act. The Respondents each have the right to request judicial review of the Final Order.

Pinnacle Lending LLC, Waln Team Funding LLC, Paul DeLette Waln Jr., Tamara Christine King - S-19-2811-20-SC01 - Statement of Charges

On May 6, 2020, the Securities Division entered a Statement of Charges against Respondents Pinnacle Lending LLC, Waln Team Funding LLC, Paul DeLette Waln Jr., and Tamara Christine King. The Securities Division alleged that Respondents had offered and sold investments to finance real estate construction projects. The Securities Division alleged that Respondents had offered and sold $325,000 of investments in Pinnacle Lending to at least two investors and more than $100,000 of investments in Waln Team Funding to at least two investors. The Securities Division alleged that Respondents each offered and sold unregistered securities and each violated the anti-fraud provision of the Securities Act of Washington by misrepresenting and by failing to disclose material information about the investments. The Statement of Charges gave notice of the Securities Division’s intent to order Respondents to cease and desist from violating the Securities Act, to impose fines, and to charge investigative costs. The Respondents each have the right to request an administrative hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on September 24, 2020.

A Consent Order was entered regarding this matter on June 09, 2020.

Halcyon Apartments CC4R, LLC and Paul DeLette Waln Jr. - S-20-2881-20-SC01 - Statement of Charges

On May 6, 2020, the Securities Division entered a Statement of Charges against Respondents Halcyon Apartments CC4R, LLC and Paul DeLette Waln Jr. The Securities Division alleged that Respondents had offered and sold a total of $1.9 million worth of Halcyon LLC membership unit investments to more than 25 investors. The Securities Division alleged that Respondents offered and sold unregistered securities. The Statement of Charges gave notice of the Securities Division’s intent to order Respondents to cease and desist from violating the Securities Act, to impose fines, and to charge investigative costs. The Respondents each have the right to request an administrative hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on September 24, 2020.

Harbour Driving School, Inc. d.b.a. Defensive Driving School and John Coburn Fawcett, Jr. a.k.a. J.C. Fawcett - S-20-2834-20-SC01 - Statement of Charges

On May 5, 2020, the Securities Division entered a Statement of Charges against Harbour Driving School, Inc. d.b.a. Defensive Driving School and John Coburn Fawcett, Jr. a.k.a. J.C. Fawcett (“Respondents”). The Securities Division alleged that the Respondents sold at least two franchises in the state and received $25,000 in payment for a license. The Securities Division alleged that the Respondents failed to register the offer and sale of a franchise with the Securities Division and failed to provide franchisees with a franchise disclosure document. The Securities Division intends to order the Respondent to cease and desist from violations of RCW 19.100.020 and RCW 19.100.080, the franchise registration and franchise disclosure document sections of the Franchise Investment Protection Act. The Respondents each have an opportunity for hearing in this matter.

A Consent Order was entered regarding this matter on September 1, 2020.

On May 1, 2020, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Impose a Fine, and to Charge Costs (Statement of Charges) against Geoffrey Wescott James a.k.a. Geoff James or Geoff Wescott, d.b.a. Veritas International Limited, d.b.a. Veritas Incorporated, d.b.a. Veritas Capital Partners, d.b.a. Aquila LTD Malta, (Respondents). The Statement of Charges alleges that the Respondents Geoff James and Veritas International Limited violated the Securities Act of Washington by offering and selling unregistered securities in the form of loans and a profit sharing interest in a gold bullion import/export venture and misrepresenting or failing to disclose material facts to an investor in violation of RCW 21.20.140 and .010 respectively. The Statement of Charges alleges that the Respondent James sold securities when not registered as a broker or securities salesperson in violation of RCW 21.20.040. The Securities Division intends to order the Respondents to cease and desist from violating the Securities Act of Washington, to impose an administrative fine, and to charge investigative costs. Respondents each have the right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on September 24, 2020.

Rhino Linings - S-19-2777-20-CO01 - Consent Order

On April 28, 2020, the Securities Division entered into a Consent Order with Respondent Rhino Linings Corporation (Rhino Linings). The Securities Division alleged in its consent order that Rhino Linings sold unregistered franchises to Washington residents when Rhino Linings sold them vehicle protection applicator agreements, and failed to provide a franchise disclosure document to these residents in the sale of its agreements. The Securities Division also alleged that Rhino Linings failed to provide a basis for financial performance representations Rhino Linings made in connection with the offer and sale of Rhino Lining’s franchises. Rhino Linings did not collect sales data from its applicators, and thus could not support its profit claims. Without admitting or denying the Securities Division’s allegations, Rhino Linings agreed to cease and desist from violations of RCW 19.100.020, the franchisee registration provision; RCW 19.100.080, the franchise disclosure document provision; and RCW 19.100.170, the violations provision of the Franchise Investment Protection Act of Washington. Rhino Linings agreed to pay investigative costs of $5,937.50 and waived its right to a hearing and judicial review of the matter.

Global Marine Exploration, Inc., Robert Henry (“Bobby”) Pritchett III, Ronald R. Alber - S-20-2872-20-SC01 - Statement of Charges

On April 24, 2020, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Impose Fines, and to Charge Costs (“Statement of Charges”) against Respondents Global Marine Exploration Inc. (“GME”), Robert (“Bobby”) Henry Pritchett II (“Pritchett”)I, and Ronald R. Alber (“Alber”). GME, whose principal place of business is currently located in Sebastian, Florida, is in the business of salvaging and recovering treasure from shipwrecks.

The Statement of Charges alleges that in January 2012, the Respondents violated the registration provisions of the Securities Act of Washington by offering and selling $27,700 worth of unregistered GME stock to a Washington investor. The Statement of Charges also alleges that Respondents violated the anti-fraud provision of the Securities Act by making untrue and misleading statements and by failing to disclose material information about the stock. The Statement of Charges gives notice of the Securities Division’s intent to order the Respondents to cease and desist from violating the Securities Act and to impose fines and charge costs against Pritchett and Alber. The Respondents may each request an administrative hearing on the Statement of Charges.

A Final Order was entered regarding this matter on September 17, 2020.

A Final Order was entered regarding this matter on January 21, 2021.

Morrow, Mark - S-20-2879-20-SC01 - Statement of Charges

On April 23, 2020, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Impose a Fine, and to Charge Costs (“Statement of Charges”) against Mark A. Morrow (“Morrow”). The Statement of Charges alleges Morrow acted as an investment adviser when he advertised trading services for compensation in several Washington Craigslist posting areas. Most recently, these advertisements promised large returns from trading off of the coronavirus pandemic. Additionally, the Statement of Charges alleges that Morrow offered unregistered securities in Washington when he offered to split profits he promised investors would make from his trading. The Statement of Charges further alleges that Morrow made false or misleading statements in his advertisements and otherwise did not provide material information necessary to make his advertisements not misleading.

Morrow is not registered as an investment adviser representative or securities salesperson in Washington. Morrow failed to respond to the Securities Division’s subpoena or take down the relevant advertisements. The Securities Division intends to order Morrow to cease and desist from violating the Securities Act of Washington, to pay a fine of $20,000.00, and to pay investigative costs of $2406.25. Morrow has a right to request a hearing on the Statement of Charges.

Ali Taj, Winchester Fund of Funds LP, Winchester Management Company LLC, Winchester Fund Advisors LLC - S-18-2524-19-SC01 - Statement of Charges

On April 22, 2020 the Securities Division (“the Division”) entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, Deny Future Registrations, Impose Fines, and Charge Costs (“Statement of Charges”) against Respondents Ali Taj (“Taj”), Winchester Fund of Funds LP (“Winchester Fund”), Winchester Management Company LLC (“Winchester Management”), and Winchester Fund Advisors LLC (“Winchester Advisors”) (collectively, “the Respondents”).

In the Statement of Charges, the Securities Division alleges that the Respondents, while residing and doing business in Washington, violated the Securities Act of Washington (“the Act”) in the course of managing Winchester Fund and in offering and selling interests therein. Specifically, the Division alleges (a) that Taj and Winchester Fund violated the securities registration provision of the Act by offering and selling approximately $1.63 million of unregistered interests in Winchester Fund; (b) that Taj and Winchester Advisors violated the securities salesperson and broker-dealer registration provisions of the Act by offering and selling interests in Winchester Fund without being appropriately registered; (c) that Taj and Winchester Management violated the investment adviser and investment adviser representative provisions of the Act by transacting business in Washington as an investment adviser or investment adviser representative without being appropriately registered; (d) that Winchester Management violated the performance-fee provision of the Act by entering into investment advisory contracts which contained performance fees prohibited by Washington law; (e) that Taj and Winchester Management violated the antifraud provisions of the Act by failing to comply with the custody requirements of the Act’s accompanying regulations; and (f) that Taj, Winchester Fund, and Winchester Advisors violated the antifraud provisions of the Act by making material misrepresentations or omissions in the offer and sale of interests in Winchester Fund.

The Statement of Charges gives notice of the Securities Division’s intent to enter an order to (a) cease and desist from violations of the Securities Act of Washington, (b) deny future applications for registration by the Respondents, (c) impose fines of $60,000, and (d) to charge investigative costs of $5,000. The Respondents have a right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on September 5, 2024.

Hong, Joseph - S-19-2798-20-FO01 -Final Order

On April 21, 2020, the Securities Division entered a Final Order to Deny Future Registrations, Impose Fines, and Charge Costs (“Statement of Charges”) against Respondent Suk Jin Hong, a/k/a Joseph Hong (CRD #6342504 (“the Respondent”)). The Securities Division previously entered a Statement of Charges against the Respondent on March 9, 2020.

The Final Order finds that the Respondent engaged in dishonest and unethical practices in the securities business by (a) knowingly overdrafting his Merrill Lynch brokerage account and transferring the proceeds to another financial institution without reasonably believing he would be able to repay the overdraft, and (b) failing to disclose the existence of a securities account to his employing firm and obtain the firm’s written consent to maintain the account. The Final Order provides that any of the Respondent’s future investment adviser representative or securities salesperson applications for registration with the Securities Division will be denied, and requires the Respondent to pay a fine of $5,000 and investigative costs of $1,000. The Respondent has the right to request judicial review of the Final Order.

San Francisco Sourdough Eatery, Inc. and Robert Lenhart - S-19-2829-20-CO01 - Consent Order

On April 21, 2020, the Securities Division entered into a Consent Order with San Francisco Sourdough Eatery, Inc. and Robert Lenhart (“Respondents”). The Securities Division alleged that Respondents failed to register the offer and sale of a franchise with the Securities Division. Without admitting or denying the Securities Division’s allegations, Respondents agree and are ordered to cease and desist from violating the Registration section of the Franchise Investment Protection Act. The Respondents waive their right to a hearing and judicial review of the matter.

Summit Wealth Solutions - S-19-2614-20-SC01 - Statement of Charges

On April 20, 2020, the Securities Division issued a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Revoke Registration, to Deny Future Registrations, to Impose Fines, and to Charge Costs (Statement of Charges) against Margaret Powers, Gordon Lee Powers, Jr., and Summit Wealth Solutions, LLC.

The Statement of Charges alleges that Margaret Powers, Gordon Lee Powers, Jr., and Summit Wealth Solutions all made unsuitable sales recommendations through their pursuit of a high-risk investment strategy in client accounts. The Statement of Charges further alleges that Margaret Powers and Summit Wealth Solutions charged clients an unreasonable fee by assessing clients an assets under management fee on static long-term cash investments. And the Statement of Charges alleges that Gordon Lee Powers, Jr. provided investment advice without being registered to do so and that, as a result, Summit Wealth Solutions unlawfully employed and associated with him. In the course of providing unregistered investment advice, the Statement of Charges also alleges that Gordon Lee Powers, Jr. misrepresented or omitted material facts.

For Margaret Powers, Gordon Lee Powers, Jr., and Summit Wealth Solutions, the Securities Division intends to order that they cease and desist from violations of the Securities Act of Washington, that their future securities registrations with the Securities Divisions be denied, and that they be liable for fines and costs. The Securities Division also intends to order that the investment adviser representative registration for Margaret Powers and the investment adviser registration for Summit Wealth Solutions each be revoked.

Margaret Powers, Gordon Lee Powers, Jr., and Summit Wealth Solutions each has a right to request a hearing on the Statement of Charges.

Donald Logan - S-19-2632-19-SC01 - Statement of Charges

On April 17, 2020, the Securities Division entered a Statement of Charges (the “order”) against Bremerton resident Donald Logan (“Logan”) who was registered with the Division as a securities salesperson and investment adviser representative of two firms from 2008 to 2018. The order alleges that Logan engaged in unethical conduct by exercising unauthorized discretion over clients’ accounts, and by misusing client forms. The order also alleges that Logan failed to make required updates of his Form U4, and that he made false filings with the Division by submitting Forms U4 that did not disclose a civil judgment against him. The order further alleges that Logan acted unethically when he did not disclose his financial interest in recommendations that he made to a client. The order gives notice of the Division’s intent to order Logan to cease and desist from violating the Washington State Securities Act, to pay the Division’s investigative costs of $2,000, and to pay a fine of $10,000. The order also gives notice of the Division’s intent to deny any investment adviser, investment adviser representative, broker-dealer, and securities salesperson registrations that Logan may seek in the future. Logan may request an administrative hearing on the order.

A Consent Order was entered regarding this matter on March 17, 2021.

Chicago Doughnut Franchise Company LLC - S-18-2406-20-SC01 - Statement of Charges

On April 6, 2020, the Securities Division entered a Statement of Charges and Notice of Intent to Order to Cease and Desist against Respondents Chicago Doughnut Franchise Company, LLC d.b.a. The Dapper Doughnut, Brian Pappas and Jeff Pappas. The Securities Division alleged that the Respondents filed a false or misleading franchise application in violation of RCW 19.100.170, the violations section of the Franchise Investment Protection Act. The Respondents each have an opportunity for hearing in this matter.

A Final Order was entered regarding this matter on May 6, 2020.

Halydean Corporation and Taylor Forrester Moffitt a.k.a. Taylor Moffitt of Halydean - S-19-2736-20-SC01 - Statement of Charges

On April 8, 2020, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Impose a Fine, and to Charge Costs (Statement of Charges) against Halydean Corporation and Taylor Forrester Moffitt a.k.a. Taylor Moffitt of Halydean (Respondents). The Statement of Charges alleges that Respondents violated the Securities Act of Washington by offering and selling unregistered Halydean stock and misrepresenting or failing to disclose material facts to investors in violation of RCW 21.20.140 and .010 respectively. The Statement of Charges alleges that Respondent Moffitt sold securities when not registered as a broker or securities salesperson in violation of RCW 21.20.040. The Securities Division intends to order Respondents to cease and desist from violating the Securities Act of Washington, to impose an administrative fine, and to charge investigative costs. Respondents have the right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on August 17, 2020.

Dai Lam Phuong, a.k.a. Dan Phuong and d.b.a. Fortpoint Investment Management - S-19-2762-20-FO01 - Final Order

On March 26, 2020, the Securities Division entered an Entry of Findings of Fact and Conclusions of Law and Final Order to Cease and Desist, to Impose Fines and to Charge Costs (“Final Order”) against Respondent Dai Lam Phuong, a.k.a. Dan Phuong and d.b.a. Fortpoint Investment Management. The Securities Division alleged that the Respondent violated the Securities Act by acting as an investment adviser and/or an investment adviser representative while not registered to do so and failing to make available books and records. The Securities Division ordered the Respondent to cease and desist from violating the Securities Act, imposed an administrative fine of $76,600, and charged investigative costs of $7,000. The Respondent has a right to request judicial review of the Final Order.

Ron Hannes – S-20-2873-20-SC01 - Statement of Charges

On March 25, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, Deny Future Registrations, Impose Fines, and Charge Costs (“Statement of Charges”) against Respondent Ronald Walter Hannes (“Hannes,” CRD #1462241). In the Statement of Charges, the Securities Division alleges that Hannes violated the Securities Act of Washington by employing a scheme to defraud his clients by selling unregistered, fictitious investments, concealing these sales from his broker-dealer, and falsifying documents in response to the broker-dealer’s internal investigation. The Securities Division further alleges that Hannes defrauded at least nineteen clients of at least $2.9 million. The Statement of Charges gives notice of the Securities Division’s intent to enter an order to cease and desist from violations of the Securities Act of Washington, to impose a fine of $100,000, to charge investigative costs of $5,000, and to deny any of Hannes’s future investment adviser representative or securities salesperson applications for registration. Hannes has the right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on September 16, 2020.

OYO Hotels, Inc. - S-19-2703-19-CO01 - Consent Order

On March 20, 2020 the Securities Division (the “Division”) entered into a Consent Order with OYO Hotels, Inc. (“OYO”). In the Consent Order, the Division alleged that OYO offered and sold nine unregistered franchises. The Division also alleged that OYO failed to provide a franchise disclosure document to its Washington franchisees in violation of the State’s Franchise Investment Protection Act (the “Act”). OYO neither admits nor denies these allegations. In settling this matter, OYO agreed to cease and desist from violating the Act, and to pay the Division $2,500 for investigative costs. OYO also waived its right to an administrative hearing and judicial review of this matter.

Get Air Management, Inc. - S-19-2816-20-CO01 - Consent Order

On March 17, 2020, the Securities Division entered into a Consent Order with Get Air Management, Inc. (Respondent). In the Consent Order, the Securities Division alleged that the Respondent violated the Franchise Investment Protection Act by offering and selling franchises in Washington, while not registered to do so. Without admitting or denying the Securities Division’s allegations, the Respondent agreed to cease and desist from the registration and franchise disclosure document portions of the Franchise Investment Protection Act. The Respondent agreed to pay investigative costs of $1,000 and waived its right to a hearing and judicial review of the matter.

Michael D. Jackson – S-17-2329-20-SC01 - Statement of Charges

On March 13, 2020, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Deny Future Registrations, to Impose a Fine, and to Charge Costs (Statement of Charges) against Michael D. Jackson (Respondent). The Statement of Charges alleges that Respondent violated the Securities Act of Washington when he advised a client to open a brokerage account for Respondent to manage away from Respondent’s firm. Respondent then engaged in speculative trading in the account, which lost all of its value. The Statement of Charges alleges that Respondent’s conduct violated RCW 21.20.020 and RCW 21.20.035. The Securities Division intends to order Respondent to cease and desist from violating the Securities Act of Washington, to deny any future securities registration applications by Respondent, to impose an administrative fine, and to charge investigative costs. Respondent has a right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on July 22, 2020.

Chalice Investments - S-18-2534-19-SC01 - Statement of Charges

On March 13, 2020, the Securities Division entered a Statement of Charges against Woodinville-based Chalice Investments, LLC (“Chalice”), Haystack 4Life, LLC (Haystack 4Life), Haystack Caps, LLC (“Haystack Caps”), as well as their principal Jeffray Lewis (“Lewis”) (collectively, “respondents”). Lewis intended Chalice to be a holding company for several marijuana-related businesses. The Statement of Charges alleges that Lewis sold $60,000 of interests in Chalice to a Washington couple. The Statement of Charges also alleges that Lewis offered interests in Haystack 4Life, and Haystack Caps in an effort to persuade a supplier to provide Lewis with more time to pay money owed to the supplier. The Division alleges that respondents violated the Washington State Securities Act by engaging in the conduct described above. The Statement of Charges gives notice of the Division’s intent to order the respondents to cease and desist from violating the Act. The Statement of Charges also gives notice of the Division’s intent to order the respondents to reimburse the Division its investigative costs, and to pay fines. The respondents may request an administrative hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on April 2, 2021.

Hong, Joseph - S-19-2798-20-SC01 - Statement of Charges

On March 9, 2020, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Deny Future Registrations, Impose Fines, and Charge Costs (“Statement of Charges”) against Respondent Suk Jin Hong, a/k/a Joseph Hong (CRD #6342504).

In the Statement of Charges, the Securities Division alleges that the Respondent engaged in dishonest and unethical practices in the securities business by (a) knowingly overdrafting his Merrill Lynch brokerage account and transferring the proceeds to another financial institution without reasonably believing he would be able to repay the overdraft, and (b) failing to disclose the existence of a securities account to his employing firm and obtain the firm’s written consent to maintain the account. The Statement of Charges gives notice of the Securities Division’s intent to enter an order to cease and desist from violations of the Securities Act of Washington, to impose a fine of $5,000, to charge investigative costs of $1,000, and to deny any of the Respondent’s future investment adviser representative or securities salesperson applications for registration. The Respondent has the right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on April 21, 2020.

Roomescape Kft. - S-19-2831-20-CO01 - Consent Order

On March 6, 2020, the Securities Division entered into a Consent Order with Roomescape Kft. (Respondent). In the Consent Order, the Securities Division alleged that the Respondent violated the Franchise Investment Protection Act by offering and selling an escape room franchise in Washington under the brand name Fox in a Box, while not registered to do so. Without admitting or denying the Securities Division’s allegations, the Respondent agreed to cease and desist from the registration and franchise disclosure document portions of the Franchise Investment Protection Act. The Respondent agreed to pay investigative costs of $500 and waived its right to a hearing and judicial review of the matter.

RChain Cooperative and Lucius Gregory Meredith - S-18-2463-20-CO01 - Consent Order

On February 28, 2020, the Securities Division entered into a Consent Order with RChain Cooperative and Lucius Gregory Meredith (“Respondents”). In the Consent Order, the Securities Division alleged that the Respondents raised approximately $30 million through the sale of a cryptographic token named RHOC in violation of the registration and anti-fraud provisions of the Securities Act of Washington. In settling the matter, the Respondents neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act. RChain Cooperative agreed to pay a fine of $50,000 and Lucius Gregory Meredith agreed to pay a fine of $25,000. The Respondents also agreed to reimburse the Securities Division $20,000 for its costs of investigation. The Respondents waived their right to a hearing and to judicial review of the matter.

Dai Lam Phuong, a.k.a. Dan Phuong and d.b.a. Fortpoint Investment Management - S-19-2762-20-SC01 - Statement of Charges

On February 26, 2020, the Securities Division entered a Statement of Charges against Respondent Dai Lam Phuong, a.k.a. Dan Phuong and d.b.a. Fortpoint Investment Management. In the Statement of Charges, the Securities Division alleged that the Respondent violated the Securities Act by acting as an investment adviser and/or an investment adviser representative while not registered to do so and failing to make available books and records. The Securities Division intends to order Respondent to cease and desist from violating the Securities Act, to impose an administrative fine, and to charge investigative costs. The Respondent has a right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on March 26, 2020.

Burgerim Group USA INC - S-20-2836-20-FO01 - Final Order

On February 13, 2020, the Securities Division issued an Entry of Findings of Fact and Conclusions of Law and Final Order Revoking Effectiveness of Registration Statement (“Final Order”) against Burgerim Group USA, Inc. (“Respondent”). The Securities Division previously entered a Stop Order against the Respondent on January 14, 2020. The Securities Division finds that Respondent violated the Franchise Investment Protection Act of Washington (“FIPA”) when it failed to amend its registration statement filed with the Securities Division within a reasonable time after the material adverse change in its financial condition and material change in its franchise disclosure document in light of its move to hire insolvency counsel to restructure its debts and appoint a Chief Restructuring Officer, and its intention to file Chapter 11 bankruptcy. The Securities Division also finds that this order is in the public interest, and the current disclosure document, as registered with the Securities Division, would work or tend to work as a fraud upon purchasers. Respondent has the right to request judicial review on the Final Order. The Stop Order remains in effect.

Asveris – S-19-2603-20-FO01 - Final Order

On February 11, 2020, the Securities Division entered a Final Order to Cease and Desist against Patrick Lawrence Kane d/b/a Asveris (“Respondent”). The Securities Division previously entered a Statement of Charges against the Respondent on January 8, 2020. The Final Order finds that Respondent violated the Franchise Investment Protection Act of Washington (“FIPA”) by offering franchises to Washington residents while not registered with the Division, and for making misleading financial performance representations. The Securities Division orders Respondent to cease and desist from violating the registration and violations sections of FIPA. Respondent has the right to request judicial review of the Final Order.

The Sound Mortgage Broker, LLC, Rochester 1-8, LLC and Bruce Philip Hills - S-18-2571-19-SC01 - Statement of Charges

On February 7, 2020, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Impose a Fine, and to Charge Costs (Statement of Charges) against The Sound Mortgage Brokers, LLC, Rochester 1-8, LLC, and Bruce Phillip Hills, a/k/a Phil Hills (Respondents). The Statement of Charges alleges that Respondents violated the Securities Act of Washington when they offered and sold about $132,250 of unregistered securities to a Washington investor. The Statement of Charges also alleges that Respondents violated the anti-fraud provision of the Securities Act by failing to disclose material information to investors. The Securities Division intends to order Respondents to cease and desist from violating the Securities Act of Washington, to impose an administrative fine, and to charge investigative costs. Respondents each have a right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on September 15, 2020.

Solium Financial Services LLC - S-20-2839-20-CO01 - Consent Order

On January 23, 2020, the Securities Division entered into a Consent Order with Respondent Solium Financial Services LLC (SFS). In connection with an investigation conducted by a multi-state taskforce of members of the North American Securities Administrators Association, the Securities Division alleged that from at least January 2009 to June 17, 2019, SFS acted as an unregistered broker-dealer in violation of RCW 21.20.040(1) when it transmitted orders for employee-participants residing in Washington as part of its equity plan administration software service for employers. SFS, without admitting or denying the findings of fact and conclusions of law, agreed to cease and desist from violations of RCW 21.20.040(1) and to pay $33,303.02 in fines and $450.00 in registration fees. SFS waived its right to a hearing and to judicial review of the matter.

American Beef Operations, LLC - S-19-2751-20-CO01 - Consent Order

On January 22, 2020, the Securities Division entered into a Consent Order with Respondent American Beef Operations, LLC. The Respondent’s principal place of business is Mercer Island, Washington. In the Consent Order, the Securities Division alleged that the Respondent offered and sold approximately $5.3 million worth of unregistered ABO LLC membership interests to more than 100 investors, including many Washington investors. The Securities Division alleged that the Respondent misrepresented the likely return on the investment and failed to disclose material information about the investment. Without admitting or denying the Securities Division’s allegations, the Respondent agreed to cease and desist from violating the registration and anti-fraud provisions of the Securities Act of Washington. The Respondent also waived its right to a hearing and to judicial review of the matter.

MotoVentures, Inc. - S-19-2704-19-CO01 - Consent Order

On January 22, 2020, the Securities Division entered into a Consent Order with MotoVentures, Inc.

The Securities Division alleged that MotoVentures violated the registration and disclosure document provisions of the Franchise Investment Protection Act of Washington, in connection with the company’s sale of a motorcycle training franchise to two Washington residents.

Without admitting or denying the Securities Division’s allegations, MotoVentures agreed to cease and desist from violating the Franchise Investment Protection Act of Washington. MotoVentures further agreed to pay $1,000 in investigative costs and waived its right to a hearing and judicial review of the matter.

iCRYO Franchise Systems LLC - S-19-2814-20-CO01 - Consent Order

On January 17, 2020, the Securities Division entered into a Consent Order with Respondent iCRYO Franchise Systems LLC (Respondent). The Respondent offers a franchise system for providing cryotherapy. The Respondent’s principal place of business is Houston, Texas. In the Consent Order, the Securities Division alleged that Respondent violated the Franchise Investment Protection Act by offering a franchise and providing financial performance representations that were outside the Franchise Disclosure Document and by failing to disclose material information about the franchise. Without admitting or denying the Securities Division’s allegations, the Respondent agreed to cease and desist from violating the disclosure provisions of the Franchise Investment Protection Act. The Respondent also agreed to pay investigative costs of $500 and waived its right to a hearing and judicial review of the matter.

Burgerim Group USA, Inc – S-20-2836-20-SO01 - Stop Order

On January 14, 2020, the Securities Division entered a Stop Order Revoking Effectiveness of Registration Statement against Burgerim Group USA, Inc. (“Respondent”). The Securities Division alleges that Respondent violated the Washington Franchise Investment Protection Act (“FIPA”) when it failed to amend its registration statement filed with the Securities Division within a reasonable time after the material adverse change in its financial condition and material change in its franchise disclosure document in light of its move to hire insolvency counsel to restructure its debts and appoint a Chief Restructuring Officer, and its intention to file Chapter 11 bankrupcy. The Securities Division also finds that this order is in the public interest, and the current disclosure document, as registered with the Securities Division would work or tend to work as a fraud upon purchasers. Respondent has the right to request a hearing on the Stop Order.

A Final Order was entered regarding this matter on February 13, 2020.

Patrick Lawrence Kane d/b/a Asveris - S-19-2603-20-SC01 - Statement of Charges

On January 8, 2020, the Securities Division Statement of Charges and Notice of Intent to Enter Order to Cease and Desist against Patrick Lawrence Kane d/b/a Asveris (“Respondent”). The Securities Division alleges that Respondent violated the Washington Franchise Investment Protection Act (“FIPA”) by offering franchises to Washington residents while not registered with the Division, and for making misleading financial performance representations while doing so. The Securities Division intends to order Respondent to cease and desist from violating the registration and violations sections of FIPA. Respondent has the right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on February 11, 2020.

Bonchon Franchise LLC - S-19-2760-19-CO01 - Consent Order

On January 6, 2020, the Securities Division entered into a Consent Order with Bonchon Franchise, LLC. In the Consent Order, the Securities Division alleged that Bonchon Franchise, LLC violated the Franchise Investment Protection Act of Washington by using a materially inaccurate Franchise Disclosure Document to sell its franchise. Without admitting or denying the Division’s allegations, Bonchon Franchise, LLC agreed to cease and desist from violating the Franchise Investment Protection Act, and to pay $250 towards the costs of the investigation. Bonchon Franchise, LLC agreed to waive their rights to a hearing and judicial review of this matter.

2020 Division of Securities Enforcement Actions

﻿Orders From Other Years

Orders From Other Years