Washington State Department of Financial Institutions

2013 Administrative Orders

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New Earth Renewable Energy Inc. and Ahava Amen – S-10-289-13-FO02 – Final Order

On December 31, 2013, the Director of the State of Washington Department of Financial Institutions entered an Order (1) Denying Petition for Review; (2) Affirmation of Findings of Fact, Conclusions of Law, and Initial Order (Dated July 31, 2013); and (3) Final Decision and Order (“Final Order”) against Respondents, New Earth Renewable Energy Inc. and Ahava Amen. The Final Order orders Respondents to each cease and desist from any further violations of RCW 21.20.010, RCW 21.20.040 and RCW 21.20.140. The Final Order also ordered Respondents to jointly and severally pay a fine of $10,000 and to jointly and severally pay investigative costs of $5,000. Respondents each have the right to petition the superior court for judicial review of the order.


Christopher Clark – S-11-0593-13-CO01 - Consent Order

On December 24, 2013, the Securities Division entered into a Consent Order with Christopher Clark. The Securities Division had previously entered a Statement of Charges against Christopher Clark on September 17, 2013. The Statement of Charges alleged that Christopher Clark violated RCW 21.20.010, RCW 21.20.040, and RCW 21.20.140 in connection with the offer and sale of unregistered securities. Without admitting or denying the Securities Division’s allegations, Christopher Clark agreed to cease and desist from violating the Securities Act of Washington and to pay investigative costs of $500. Christopher Clark waived his right to a hearing and judicial review of this matter.


Charles Jason Price; Stephen Christopher Peterson; CAC Enterprises Inc, Mr. Clean A Can – S-13-1184-13-CO01 – Consent Order

On December 16, 2013, the Securities Division entered into a Consent order with Stephen C. Petersen, Charles J. Price, and CAC Enterprises, Inc. d.b.a. Mr. Clean A Can, (collectively the respondents). The Securities Division had previously issued a Statement of Charges against the Respondents on November 21, 2013, alleging that the Respondents, in connection with the offer and sale of Mr. Clean A Can franchises, violated the registration, disclosure and anti-fraud provisions of the Franchise Investment Protection Act of Washington. Without admitting or denying the allegations, the Respondents each agreed to cease and desist from violating the Franchise Investment Protection Act of Washington. The Respondents further agreed to pay $2,300 in investigative costs. The Respondents each waived their right to a hearing and judicial review of the matter.


David Gintz; Jenning Development, LLC; Jenning Investment One, LLC; Jenning Investment Two, LLC; Gintz & Toner, LLC – S-11-0620-13-CO07 – Consent Order

On December 12, 2013 the Securities Division entered into a Consent Order with David Gintz; Jenning Development, LLC; Jenning Investment One, LLC; Jenning Investment Two, LLC; and Gintz & Toner, LLC (collectively “Respondents”). The Securities Division had previously entered a Statement of Charges (S-11-0620-13-SC02) against the Respondents on May 31, 2013. The Securities Division alleged that Respondents violated RCW 21.20.010, RCW 21.20.040, and RCW 21.20.140 in connection with the offering of unregistered securities related to real estate. Without admitting or denying the Securities Division’s allegations, Respondents agreed to cease and desist from violating the Washington Securities Act. David Gintz agreed to pay a fine of $5,000. Respondents waived their right to a hearing and judicial review of this matter.


David Gintz; Gintz Group, LLC; 2681 Central Terrace, LLC; 705 East Republican, LLC; 1550 North Parkway, LLC; 755 Broadway, LLC; 1052 South 27th Street, LLC; 27th Street Station, LLC; Gintz Group Equity Fund, LLC; Gintz Group Development, LLC – S-11-0620-13-CO06 – Consent Order

On December 12, 2013 the Securities Division entered into a Consent Order with David Gintz; Gintz Group, LLC; 2681 Central Terrace, LLC; 705 East Republican, LLC; 1550 North Parkway, LLC; 1052 South 27th Street , LLC; 27th Street Station, LLC; Gintz Group Equity Fun, LLC; and Gintz Group Development, LLC (collectively “Respondents”). The Securities Division had previously entered a Statement of Charges (S-11-0620-13-SC01) against the Respondents on May 31, 2013. The Securities Division alleged that Respondents violated RCW 21.20.010, RCW 21.20.040 and RCW 21.20.140 in connection with the offering of unregistered securities related to real estate. Without admitting or denying the Securities Division’s allegations, Respondents agreed to cease and desist from violating the Washington Securities Act. David Gintz agreed to pay a fine of $5,000. Respondents waived their right to a hearing and judicial review of this matter.


Xanadu, Inc. - S-11-0818-13-FO01 – Final Order

On December 12, 2013, the Securities Division entered a Final Order to Cease and Desist, Denying Exemption, and Revoking Exemptions against Xanadu, Inc. The Securities Division previously entered a Summary Order against Xanadu Inc. on October 13, 2011. Xanadu, Inc. was formed to build a private vacation club and sought to offer common stock in the company to reserve memberships in the proposed club. Xanadu, Inc. filed a Notification of Claim Exemption with the Securities Division pursuant to RCW 21.20.320(16)(a)(ii) to claim the exemption from securities registration for transactions by a mutual or cooperative association. The Order alleged that Xanadu, Inc. did not meet the requirements for the exemption claimed. The Order further alleged that the offering documents posted by Xanadu, Inc. on its website contained misstatements or omissions of material information. The Securities Division enters an Order denying the exemption for mutual or cooperative associations and orders Xanadu, Inc. to cease and desist from violating the Securities Act of Washington and revokes the exemptions under RCW 21.20.320(1), (9), (16), and (17) with respect to securities offered by Xanadu, Inc. Xanadu, Inc. has a right to request judicial review of the Final Order.


TV Liberty Investments, LLC and Thomas G. Biehl – S-12-1108-13-CO01 – Consent Order

On December 5, 2013, the Securities Division entered into a Consent Order with TV Liberty Investments, LLC and Thomas G. Biehl (“Respondents”), who did business in the Yakima Valley. The Securities Division alleged that, in connection with the offer and sale of promissory note investments, Respondents each failed to disclose material information to investors. The Securities Division alleged that Respondents offered and sold more than $2.7 million worth of investments to at least nineteen investors from at least 1999 through 2009. Without admitting or denying the Securities Division’s allegations, the Respondents each agreed to cease and desist from violating the registration and anti-fraud provisions of the Securities Act of Washington. The Respondents each waived their right to a hearing and to judicial review of the matter.


Discovery Tours, LLC and Melody Miranda – S-09-448-13-CO01 - Consent Order

On November 22, 2013, the Securities Division entered into a Consent Order with Discovery Tours, LLC and Melody Miranda (collectively the Respondents). The Securities Division had previously entered a Statement of Charges against the Respondents alleging that from 2005 to 2009, Respondents raised over $1.5 million through the offer and sale of investments that were referred to as “Growth Notes,” “Growth Certificates,” “Expansion Notes,” and “Mortgage Notes.” The Statement of Charges further alleged that the Respondents each violated the Securities Act’s provisions regarding the registration of securities, broker-dealers and salespersons and violated the anti-fraud provisions of the Act. Without admitting or denying the Securities Division’s allegations, Respondents agreed to cease and desist from violating the Washington Securities Act and waived their rights to a hearing and to judicial review of the matter.


Stephen C. Peterson, Charles J. Price, and CAC Enterprises, Inc. d.b.a. Mr. Clean A Can - S-13-1184-13-SC01 - Statement of Charges

On November 21, 2013, the Securities Division entered a Statement of Charges and Notice of Intent to Enter an Order to Cease and Desist against Respondents Stephen Christopher Peterson, Charles Jason Price and CAC Enterprises, Inc. d.b.a. Mr. Clean A Can, alleging that the Respondents violated the Franchise Investment Protection Act by offering and selling a trash can cleaning franchise in Washington. Respondents were not registered to sell franchises and the franchise was neither registered nor exempt from registration. Further, Respondents failed to provide investors with a franchise disclosure document and material information regarding the investment. The Securities Division intends to order the Respondents to cease and desist from violations of RCW 19.100.020, RCW 19.100.080 and RCW 19.100.170, the registration, disclosure document and anti-fraud portions 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 December 16, 2013.


Ronald Newman, Jeffrey Scott Hollingsworth, Milestone Life Settlement Fund, LLC, Milestone Investments USA, LLC, and Milestone Multifamily Fund, LLC - S-12-1060-13-SC01 - Statement of Charges

On November 18, 2013, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Impose Fines, to Charge Costs, and to Deny Future Registrations (Statement of Charges) against Respondents Ronald Newman, Jeffrey Scott Hollingsworth, Milestone Life Settlement Fund, LLC, Milestone Investments USA, LLC, and Milestone Multifamily Fund, LLC.

The Statement of Charges alleges that Ronald Newman and Jeffrey Hollingsworth violated the registration and anti-fraud provisions of the Securities Act of Washington in their efforts to raise capital for a fund that invested in life insurance policies and a fund that sought to develop and sell rental properties. The Statement of Charges further alleges that Ronald Newman and Jeffrey Hollingsworth acted through Milestone Investments USA, LLC when they solicited investments in these funds and that they misrepresented or failed to disclose material information to investors in the course of soliciting investments in these funds.

The Securities Division intends to order each Respondent to cease and desist from violating the Securities Act of Washington and gives notice of its intent to impose a fine and to charge costs. The Statement of Charges also reflects the Securities Division’s intent to deny any future registrations that Jeffrey Hollingsworth may file with the Securities Division. Respondents each have a right to request a hearing on the Statement of Charges.


Capital Business Consultants, LLC and Capital Business Brokers, LLC - S-13-1271-13-CO01 - Consent Order

On November 14, 2013, the Securities Division entered into a Consent Order with Capital Business Consultants, LLC and Capital Business Brokers, LLC (collectively, the Respondents). The Securities Division alleged that the Respondents, in connection with their offer and sale of Capital Business Solutions franchises, violated the registration and anti-fraud provisions of the Franchise Investment Protection Act of Washington. Without admitting or denying the Securities Division’s allegations, the Respondents each agreed to cease and desist from violating the Franchise Investment Protection Act of Washington. The Respondents further agreed to pay $2,000 in investigative costs. The Respondents each waived their right to a hearing and judicial review of the matter.


Salon Professional Education Company, LLC d/b/a S.P.E.C. LLC, f/k/a APS, LLC - S-13-1358-13-CO01 - Consent Order

On November 13, 2013, the Securities Division entered into a Consent Order with Salon Professional Education Company, LLC d/b/a S.P.E.C. LLC, f/k/a APS, LLC (“SPEC”). In the Consent Order, the Securities Division alleged that SPEC sold an unregistered franchise in the state of Washington, and that it failed to provide the franchisee with a Franchise Disclosure Document. It also alleged that SPEC failed to disclose the presence of the Washington franchisee in its franchise registration application. The Consent Order alleged that this conduct by SPEC violated the Franchise Investment Protection Act of Washington. Without admitting or denying the allegations, SPEC agreed to cease and desist from violating the Franchise Investment Protection Act. SPEC further agreed to reimburse the Securities Division $1,000 for its costs of investigation. SPEC waived its right to a hearing and judicial review of the matter.


RBC Capital Markets LLC - S-13-1276-13-CO01 - Consent Order

On November 1, 2013, the Securities Division entered into a Consent Order with RBC Capital Markets, LLC (RBC) to settle allegations related to RBC salespersons accepting orders from clients in Washington State when the salespersons were not registered in the state. The Division alleged that RBC failed to reasonably supervise its salespersons in violation of RCW 21.20.110(1)(j), and that RBC employed unregistered salespersons in violation of RCW 21.20.110(1)(b). RBC neither admitted nor denied the Division’s allegations. RBC undertook and agreed to establish and maintain policies, procedures, and systems that would ensure RBC salespersons would only accept client orders from states in which they were registered. Further, RBC agreed to pay a fine of $45,140.17 and waived its right to a hearing and judicial review of the matter.


Dustin Lee Settle – S-12-1127-13-CO01 – Consent Order

On October 30, 2013, the Securities Division entered into a Consent Order with Dustin Lee Settle (Settle). The Securities Division had previously issued a Statement of Charges, S-12-1127-12-SC01, against Settle. The Securities Division alleged that Settle filed six Form U4 disclosure amendments with the Securities Division that falsely answered and/or failed to disclose at least five financial compromises, a federal tax lien, two felony charges, and/or a felony conviction. It alleged that, by filing an amendment to his Form U4 that contained misleading information, Settle made a false filing with the Securities Division in violation of RCW 21.20.350. The Statement of Charges alleged that Settle had an obligation under WAC 460-22B-060 to update his Form U4 within 30 days of any event that would make his Form U4 inaccurate. The Statement of Charges further alleged that Settle failed to comply with three FINRA rules and engaged in dishonest or unethical practices as defined by WAC 460-22B-090(19) and RCW 21.20.110(1)(g). The Statement of Charges also alleged that Settle was suspended by FINRA, and that Settle’s felony conviction involved moral turpitude. Without admitting or denying the Securities Division’s allegations, Settle has agreed to cease and desist from violating the Washington Securities Act. The Consent Order imposes a $10,000 fine against Settle. In addition, the Consent Order requires Settle to pay investigative costs of $2,500. Settle waived his right to a hearing and judicial review of the matter.


Barrett, Stephen - S-13-1167-13-SC01 - Statement of Charges

On October 25, the Securities Division entered Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Impose Fines, to Charge Costs, and to Revoke Registrations (the “Statement of Charges”) against Envision Retirement, LLC (“Envision”), Cirrus Partners, Inc. (“Cirrus”), MRG International, Inc. (“MRG”), and Stephen J. Barrett (“Barrett”) (collectively, “Respondents”). The Statement of Charges alleges that MRG and Cirrus, through Barrett, each sold approximately $3 million worth of promissory notes to Washington residents to support a cloud computing business. The Statement of Charges further alleges that MRG, Cirrus, and Barrett each violated the Securities Act of Washington (the “Act”) during these offerings. Further, the Statement of Charges alleges that Envision (Barrett’s registered investment advisory business) and Barrett each violated provisions of the Act and of the Washington Administrative Code intended to protect clients of investment advisers in recommending MRG’s and Cirrus’s notes to advisory clients. The Statement of Charges gives notice of the Division’s intent to order the Respondents to cease and desist from violating the Act, to impose fines, and to charge costs. The Statement of Charges also gives notice of the Division’s intent to revoke Envision’s investment adviser registration and Barrett’s investment adviser representative registration. 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 05, 2014.

A Consent Order as to Envision Retirement LLC and Stephen J. Barrett was entered on March 10, 2014.


SPF, INC; Fredric P. Sjoholm - S-13-1343-13-CO01 - Consent Order

On October 23, 2013, the Securities Division entered into a Consent Order with SPF, INC and Fredric P. Sjoholm. The Consent Order alleges that SPF, Inc acted as an unregistered investment adviser and Mr. Sjoholm acted as an unregistered investment adviser representative. SPF, INC and Mr. Sjoholm agreed to ceases and desist from violating the Securities Act of Washington. The Respondents also agreed to pay a fine of $10,000. The Respondents waived their rights to a hearing and judicial review of the matter.


UBS Financial Services, Inc. - S-13-1311-13-CO01 - Consent Order

On October 22, 2013, the Securities Division entered into a Consent Order with UBS Financial Services, Inc. ("Respondent"), in connection with Respondent’s alleged failure to properly register its Client Service Associates in necessary jurisdictions, including Washington State. The Division alleged that Respondent failed to reasonably supervise its agents by not establishing an adequate system to monitor the registration status of persons accepting client orders and by not enforcing its established written procedures regarding the registration requirement of Client Service Associates. The Division further alleged that such conduct resulted in Respondent’s employment of unregistered securities salespersons. The Division also alleged that UBS failed to maintain all books and records when its order tickets did not accurately identify the employee who accepted client orders. Respondent neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act of Washington. Respondent agreed to pay $80,432.53 as a civil monetary penalty. Respondent waived its right to a hearing and to judicial review of this matter.


JFB Capital LLC; Jason F. Bond - S-12-0958-13-CO02 – Consent Order

On October 18, 2013, the Securities Division entered into a Consent Order with JFB Capital LLC and Jason F. Bond (“Respondents”). The Consent Order alleged that the Respondents violated the Securities Act of Washington by failing to maintain JFB Capital LLC’s minimum financial requirements and violated a previous Securities Division Consent Order. Previously, on May 11, 2013, the Securities Division entered a Summary Order for the same violation against Respondents. In the Consent Order, the Securities Division vacated the Summary Order, except to the extent the findings and conclusion in that Summary Order were incorporated into the Consent Order. In the Consent Order the Respondents agreed to the revocation of JFB Capital LLC’s investment adviser and Jason F. Bond’s investment adviser representative registrations, a five-year prohibition on investment adviser or broker-dealer registration (with restrictions thereafter), and a twelve-month prohibition on investment adviser representative or broker-dealer salesperson registration (with restrictions thereafter). Respondents further agreed to pay a fine to the Securities Division of $3,000. Respondents waived their right to a hearing and judicial review of the matter.


John Joseph Sanchez - S-12-1076-13-SC01 - Statement of Charges

On October 18, 2013, the Securities Division entered a Statement of Charges and Notice of Intent to Enter an Order to Cease and Desist, Impose a Fine, and Charge Costs (“Statement of Charges”) against Respondent, John Joseph Sanchez. The Securities Division alleged that Respondent violated RCW 21.20.010, the anti-fraud provision of the Securities Act of Washington, by offering and selling two investments totaling $110,000 and by failing to disclose material information about the investments, including the risks of the investments. The Securities Division intends to order Respondent to cease and desist from violating the Securities Act of Washington, to impose a fine, and to charge costs. Respondent has the right to request a hearing on the Statement of Charges.


Satyen Chatterjee; Strategic Capital Management, Inc. – S-12-1059-13-TO01 – Summary Order

On October 17, 2013, the Securities Division entered a Summary Order Suspending Investment Adviser and Investment Adviser Representative Registrations and Notice of Intent to Revoke Registrations, to Impose Fines, and to Recover Costs (“the Order”) against Strategic Capital Management, Inc., a registered investment adviser, and Satyen Chatterjee, the firm’s owner and sole investment adviser representative (“the Respondents”). The Order alleges that the Respondents made material misrepresentations and omissions to investors in the offer and sale of unregistered promissory note investments in violation of the registration and anti-fraud provisions of the Securities Act of Washington. The Order further alleges that the Respondents caused false or misleading filings to be made with the Securities Division, failed to keep the books and records required of investment advisers, failed to maintain the minimum financial requirement, and engaged in one or more dishonest or unethical practices, by providing guarantees to clients. The Securities Division orders the suspension of Strategic Capital Management, Inc.’s investment adviser and Satyen Chatterjee’s investment adviser representative registrations, and gives notice of the Securities Division’s intent to revoke those registrations, to impose fines, and to charge costs. Respondents have the right to request a hearing on the Order.

A Consent Order was entered regarding this matter on June 16, 2014.


Mulligan Capital Inc.; Mulligan Capital Management, LLC; Mulligan Partners, ERISA, LP, John Mulligan – S-11-0770-12-CO01 – Consent Order

On October 14, 2013, the Securities Division entered into a Consent Order with Mulligan Capital, Inc. (“MCI”), Mulligan Capital Management, LLC (“MCM, LLC”), Mulligan Partners, ERISA, LP (“MP, LP”), and John Mulligan (“Mulligan”) (collectively, “Respondents”). The Division had previously issued a Statement of Charges against Respondents on January 30, 2012, alleging that, beginning no later than 2003, MCI provided investment advisory services to Washington residents while not registered to do so. The Statement of Charges further alleged that MP, LP, through Mulligan, offered and sold at least $748,000 worth of its limited partnership interests to at least ten Washington residents and that MCM, LLC, in its capacity as investment advisor to MP, LP, entered into performance-based fee agreements with at least six Washington investors who were not “qualified clients” as defined in Rule 205-3 of the Investment Advisors Act of 1940. The Securities Division also alleged that MCI and MCM, LLC made false or misleading statements in documents filed with the Securities Division. The Statement of Charges alleged that this conduct violated various provisions of the Securities Act of Washington (the “Act”). In entering into the Consent Order, Respondents neither admitted nor denied the allegations, agreed to cease and desist from violating the Act, and waived their rights to an administrative hearing on and to judicial review of this matter.


Richard Michael Lininger; NACAD, LLC; Mexcanusa Management Services, LTD; and Mexcanusa Development Corporation, S.A. de C.V. – S-12-1124-13-FO01 – Final Order

On October 14, 2013, the Securities Division entered a Final Order against Respondents Richard Michael Lininger, NACAD, LLC, Mexcanusa Management Services, LTD, and Mexcanusa Development Corporation, S.A. de C.V. The Securities Division had previously entered a Statement of Charges against the Respondents alleging that they violated the Securities Act of Washington in connection with Richard Michael Lininger’s efforts to raise capital to build an RV Park in Mexico. The Final Order orders the Respondents to cease and desist from violations of the registration and anti-fraud provisions of the Securities Act of Washington, and it orders Richard Michael Lininger to pay the Securities Division fines and costs. The Respondents have the right to request judicial review of the Final Order.


Runaway Hearts Productions, LLC; Canyon Sands Productions, Inc.; and Scott Sandsberry - S-13-1159-13-SC01 - Statement of Charges

On October 14, 2013, 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 Runaway Hearts Productions, LLC (Runaway Hearts); Canyon Sands Productions, Inc.; and Scott Sandsberry (collectively, Respondents). The Securities Division alleges that Respondents violated RCW 21.20.040 and RCW 21.20.140 when they offered or sold unregistered securities in the form of limited liability company interests in Runaway Hearts. Further, the Securities Division alleges that Respondents violated RCW 21.20.010 by failing to disclose material information about the investment to investors. The Securities Division intends to order the Respondents to cease and desist from violating the Securities Act of Washington, to impose fines, and to charge costs. Respondents each have a right to request a hearing on the Statement of Charges.


Human Healthy Vending (Nutrition Without Borders) - S-12-1079-13-CO01 - Consent Order

On October 11, 2013, the Securities Division entered into a Consent Order with Nutrition Without Borders, LLC dba H.U.M.A.N. Healthy Vending. The Securities Division had previously entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist ("Statement of Charges") against Nutrition Without Borders, LLC dba H.U.M.A.N. Healthy Vending and Sean Kelly. The Securities Division alleged that Nutrition Without Borders, LLC dba H.U.M.A.N. Healthy Vending sold an unregistered vending machine business opportunity in violation of the registration, disclosure document, and anti-fraud provisions of the Business Opportunity Fraud Act. Without admitting or denying the Securities Division’s allegations, Nutrition Without Borders, LLC dba H.U.M.A.N. Healthy Vending agreed to cease and desist from violating the Business Opportunity Fraud Act and to pay investigative costs of $5,000. Nutrition Without Borders, LLC dba H.U.M.A.N. Healthy Vending waived its right to a hearing and judicial review of this matter.


Michael Gintz (Gintz Group) - S-11-0620-13-CO05 - Consent Order

On October 3, 2013, the Securities Division entered into a Consent Order with Michael Gintz. The Securities Division had previously entered a Statement of Charges against Michael Gintz on May 31, 2012. The Securities Division alleged that Michael Gintz violated RCW 21.20.010, RCW 21.20.040 and RCW 21.20.140 in connection with the offering of unregistered securities related to real estate. Without admitting or denying the Securities Division’s allegations Michael Gintz agreed to cease and desist from violating the Washington Securities Act. Michael Gintz agreed to pay an administrative fine of $3,000 and investigative costs of $3,000. Michael Gintz waived his right to a hearing and judicial review of this matter.


Brad S. Sessler; Theodore J. Greene; Raindrop Capital LLC - S-13-1219-13-CO01 – Consent Order

On October 2, 2013, the Securities Division entered into a Consent Order with Brad S. Sessler, Theodore J. Greene, and Raindrop Capital, LLC. The Consent Order alleges that Mr. Sessler acted as an unregistered investment adviser representative, that Mr. Greene failed to reasonably supervise Mr. Sessler, and that Raindrop Capital, LLC associated with an unregistered investment adviser representative. Mr. Sessler and Mr. Greene agreed to a censure for these actions and the Respondents agreed to pay a fine of $500. Respondents waived their rights to a hearing and judicial review of the matter.


Ra Ghala Corporation; AuJeune Corporation; and Ray Willis - S-12-1039-13-CO01 - Consent Order

On September 20, 2013, the Securities Division entered into a Consent Order with Ra Ghala Corporation, AuJeune Corporation, and Ray Willis (collectively, the Respondents). The Securities Division alleged that the Respondents violated the registration and anti-fraud provisions of the Securities Act of Washington. Without admitting or denying the Securities Division’s allegations, the Respondents each agreed to cease and desist from violating the Securities Act of Washington. The Respondents further agreed to pay and administrative fine of $4,000 and investigative costs of $2,500. The Respondents each waived their right to a hearing and judicial review of the matter.


Pangean Energy, LLC; Bart Sweazea; Ray Valdez – S-13-1182-13-CO01 – Consent Order

On September 20, 2013, the Securities Division entered into a Consent Order with Bart Sweazea, Pangean Energy, LLC, and Ray Valdez (collectively “Respondents”). The Securities Division had previously entered a Statement of Charges against Respondents on July 2, 2013. The Securities Division alleged that Respondents violated RCW 21.20.040 and RCW 21.20.140 when they offered or sold unregistered oil and gas investments to Washington State residents, and that Respondents violated RCW 21.20.010, the anti-fraud provision of the Washington Securities Act. Without admitting or denying the Division’s allegations, Respondents agreed to cease and desist from violating the Securities Act of Washington. Further, Respondents agreed to pay an administrative fine of $10,000 and investigative costs of $2,000. Respondents waived their right to a hearing and judicial review of the matter.


iCooper, Inc – S-11-0593-13-SC01 – Statement of Charges

On September 17, 2013, 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 iCooper, Inc.; Ken Hines; and Christopher Clark (“Respondents”). The Statement of Charges alleges that Respondents offered and sold over $985,000 of iCooper stock to over 25 investors. The Statement of Charges further alleges that Respondents offered and sold unregistered securities and Ken Hines and Christopher Clark acted as unregistered securities salespersons or broker-dealers in violation of the Securities Act of Washington. The Statement of Charges also alleges that Respondents violated the anti-fraud provisions of the Securities Act of Washington. The Securities Division intends to order Respondents to cease and desist from violating the Securities Act of Washington, and gives notice of its intent to impose fines and charge costs. Respondents have a right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on January 30, 2014.

A Consent Order as to Christopher Clark was entered on December 24, 2013.


Deb Townsend – S-11-0620-13-CO04 - Consent Order

On September 17, 2013, the Securities Division entered into a Consent order with Deb Townsend. The Securities Division had previously entered a Statement of Charges against Deb Townsend on May 31, 2013. The Securities Division alleged that Deb Townsend violated RCW 21.20.010, RCW 21.20.040 and RCW 21.20.140 in connection with the offering of unregistered securities related to real estate. Without admitting or denying the Securities Division’s allegations, Deb Townsend agreed to cease and desist from violating the Washington Securities Act. Deb Townsend waived her right to a hearing and judicial review of this matter.


NDG/Maxime Albi - S-09-163-10-CO06 - Consent Order

On September 11, 2013, the Securities Division entered into a Consent Order, S-09-163-10-CO06, with Maxime Albi. Previously, on May 21, 2010, the Securities Division entered a Statement of Chages S-09-163-10-SC01, against NDG Investment Group, LLC (NDG), Mr. Albi and others (collectively the Respondents). The Statement of Charges alleged that the Respondents sold investments in the form of partnership agreements, limited liability company interests and promissory notes for the purpose of constructing residential and commercial real estate developments in Lima, Peru. The Statement of Charges alleged that the Respondents raised over $15,000,000 from over 100 investors from 2006 to 2009. The Statement of Charges alleged that Respondents offered unregistered securities, acted as unregistered broker-dealers or securities salespersons, and violated the anti-fraud provisions of the Securities Act of Washington. In settling the matter, Mr. Albi, a former NDG independent contractor and investor, agreed, without admitting or denying the findings of fact, to cease and desist from violating the Securities Act of Washington. Mr. Albi waived his rights to a hearing or other further proceedings in the matter.


Cecilia Cabasco Sawyer - S-13-1154-13-CO01 - Consent Order

On September 11, 2013, the Securities Division entered into a Consent Order with Cecilia Cabasco Sawyer, aka Cecilia Cabasco Villanueva (Sawyer). The Securities Division had previously entered a Statement of Charges against Sawyer on March 29, 2013. The Securities Division alleged that Sawyer falsely claimed a client’s annuity death benefit, opened a bank account under the client’s name, forged checks on the bank account, and withdrew funds for her own benefit. Without admitting or denying the Division’s allegations, Sawyer agreed that the Securities Division will deny any broker-dealer, securities salesperson, investment adviser, or investment adviser representative registration application she may file in the future. Sawyer waived her right to a hearing and judicial review of this matter.


Showdown Partners, LLC; Express Entertainment, Inc; Kenneth Kinnear, George Todd - S-11-0688-13-CO01 - Consent Order

On September 10, 2013, the Securities Division entered into a Consent Order with George Todd. The Securities Division had previously entered a Statement of Charges against George Todd on July 3, 2013. The Securities Division alleged that George Todd violated RCW 21.20.010, RCW 21.20.040 and RCW 21.20.140 in connection with the offering of unregistered securities. Without admitting or denying the Securities Division’s allegations, George Todd agreed to cease and desist from violating the Securities Act of Washington. George Todd agreed to pay an administrative fine of $5,000 and investigative costs of $1,000. George Todd waived his right to a hearing and judicial review of this matter.


2344-2345 Franklin Twins, LLC - S-10-047-12-CO04 - Consent Order

On August 28, 2013, the Securities Division entered into a Consent Order with 2344-2345 Franklin Twins, LLC ("Respondent"). The Consent Order alleges that from approximately April 2008 through October 2008, Gregory Pinneo ("Pinneo") offered and sold approximately $708,000 worth of LLC membership interests in 2344-2345 Franklin Twins, LLC. The Consent Order also alleges that when offering and selling the membership interests, Pinneo omitted to disclose material information about the investment. Without admitting or denying the allegations, Respondent agreed to cease and desist from any violation of the registration and the anti-fraud provisions of the Securities Act of Washington. Respondent waived its right to a hearing and to judicial review of the matter.


Franklin Avenue Partners, LLC - S-10-047-12-CO02 - Consent Order

On August 28, 2013, the Securities Division entered into a Consent Order with Franklin Avenue Partners, LLC ("Respondent"). The Consent Order alleges that from approximately July 2006 through November 2006, Gregory Pinneo ("Pinneo") raised approximately $900,000 from approximately 17 investors through the offer and sale of membership interests in Franklin Avenue Partners, LLC. The Consent Order also alleges that when offering and selling the membership interests, Pinneo omitted to disclose material information about the investment. Without admitting or denying the allegations, Respondent agreed to cease and desist from any violation of the registration and the anti-fraud provisions of the Securities Act of Washington. Respondent waived its right to a hearing and to judicial review of the matter.


Ronald Gintz – S-11-0620-13-CO03 – Consent Order

On August 15, 2013, the Securities Division entered into a Consent Order with Ronald Gintz. The Securities Division had previously entered a Statement of Charges against Ronald Gintz on May 31, 2013. The Securities Division alleged that Ronald Gintz violated RCW 21.20.010, RCW 21.20.040 and RCW 21.20.140 in connection with the offering of unregistered securities related to real estate. Without admitting or denying the Securities Division’s allegations Ronald Gintz agreed to cease and desist from violating the Washington Securities Act. Ronald Gintz agreed to pay an administrative fine of $7,500 and investigative costs of $2,500. Ronald Gintz waived his right to a hearing and judicial review of this matter.


SearchPath International, Inc. - S-12-1084-13-CO01 - Consent Order

On August 6, 2013, the Securities Division entered into a Consent Order with SearchPath International, Inc. and Pathfinder Search Partners of Cleveland, Inc. d/b/a SearchPath of Cleveland Uptown (collectively, Respondents). The Securities Division had previously issued a Statement of Charges, S-12-1084-12-SC01, against Respondents. The Securities Division alleged that Respondents violated the registration, disclosure document, and anti-fraud provisions of the Washington State Franchise Protection Act (the Act). Without admitting or denying the Securities Division’s allegations, Respondents each agreed to cease and desist from violating the registration, disclosure document, and anti-fraud provision of the Act. Respondents further agreed to reimburse the Securities Division $1,500 for its costs of investigation. Respondents each waived their right to a hearing and judicial review of the matter.


Money Now Funding, LLC - S-13-1198-13-FO01 - Final Order

On August 2, 2013, the Securities Division entered a Final Order against Leary Darling, US Doc Assist, LLC, and Legal Dox, LLC. The Securities Division had previously entered a Statement of Charges against Leary Darling, Maria Sebastiana Hobbs a/k/a Anna Hobbs, Vanessa Hobbs, Money Now Funding, LLC, US Doc Assist, LLC, and Legal Dox, LLC, alleging that the Respondents violated the Business Opportunity Fraud Act through their offer and sale of a Money Now Funding business opportunity to a Washington resident. The Final Order orders Leary Darling, US Doc Assist, LLC, and Legal Dox, LLC to cease and desist from violating the registration, disclosure document, and anti-fraud provision of Business Opportunity Fraud Act. Leary Darling, US Doc Assist, LLC, and Legal Dox, LLC have the right to request judicial review of the Final Order.


Richard Michael Lininger; NACAD, LLC; Mexcanusa Management Services, LTD; and Mexcanusa Development Corporation, S.A. de C.V. - S-12-1124-13-SC01 - Statement of Charges

On July 30, 2013, 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 Richard Michael Lininger; NACAD, LLC, Mexcanusa Management Services, LTD, and Mexcanusa Development Corporation, S.A. de C.V. The Statement of Charges alleges that Richard Michael Lininger violated the registration and anti-fraud provisions of the Securities Act of Washington when he solicited investments to build an RV Park in Mexico. The Securities Division intends to order the Respondents to cease and desist from violating the Securities Act of Washington and gives notice of its intent to impose a fine and to charge costs. Respondents each have a right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on October 14, 2013.


Glenn Anthony Walker - S-12-0990-13-CO01 - Consent Order

On July 30, 2013, the Securities Division entered into a Consent Order with Glenn Anthony Walker (Walker). The Securities Division had previously entered a Statement of Charges against Walker, alleging that Walker violated the registration and anti-fraud provisions of the Securities Act of Washington, when he solicited investments in Varro Seattle LLC. Without admitting or denying the Securities Division’s allegations, Walker agreed to cease and desist from violating the Securities Act of Washington and pay investigative costs of $500.00. Walker also waived his right to a hearing and judicial review of this matter.


Rafael Vasquez d/b/a Rafael Vasquez Investments & Securities L.L.C. - S-13-1155-13-FO01 - Final Order

On July 30, 2013, the Securities Division entered a Final Order against Rafael Vasquez d/b/a Rafael Vasquez Investments & Securities L.L.C. ("Vasquez"). The Division had previously entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Impose a Fine, to Charge Costs, and to Deny Future Registrations (the "Statement of Charges") against Vasquez. The Statement of Charges alleged that Vasquez held himself out as an investment adviser while not registered as such, or exempt from such registration, in Washington. The Statement of Charges further alleged that, in doing so, Vasquez violated the section of the Washington Securities Act requiring registration of investment advisers. The Final Order orders Vasquez to cease and desist, imposes a fine, charges the Division’s investigative costs, and denies any investment adviser registration and investment adviser representative registration that Vasquez may seek in the future. Vasquez may seek judicial review of the Final Order.


TNK Mortgage Service, LLC, Michael Roy Thacker a/k/a Mike Thacker and William Forrest Knoppi a/k/a Bill Knoppi - S-09-467-13-CO01 - Consent Order

On July 30, 2013, the Securities Division entered into a Consent Order with TNK Mortgage Service, LLC and Michael Roy Thacker, Respondents. The Securities Division had previously issued a Statement of Charges against TNK Mortgage Service, LLC, Michael Roy Thacker a/k/a Mike Thacker and William Forrest Knoppi (Knoppi) a/k/a Bill Knoppi. In the Statement of Charges, Securities Division had alleged that Respondents each represented to investors that they could invest in promissory notes that would be secured by interests in real property. The Securities Division also alleged that in 2007, Respondents offered and sold more than $700,000 of promissory note investments to three Washington residents. The Securities Division further alleged that in the offer and sale of the promissory note investments, Respondents each violated the anti-fraud provision of the Securities Act of Washington by misrepresenting or failing to disclose material information to the investors. Without admitting or denying the Securities Division’s allegations, Respondents TNK Mortgage Service, LLC and Michael Roy Thacker agreed to cease and desist from violating the Washington Securities Act and waived their right to a hearing and to judicial review of this matter.


Strategic I, LLC; Strategic IV, LLC; SAAM Realty, LLC; Edward R. Zumwalt - S-09-020-13-CO01 - Consent Order

On July 9, 2013, the Securities Division entered into a Consent Order, S-09-020-13-CO01, with Strategic I, LLC; Strategic IV, LLC; SAAM Realty, LLC; and Edward R. Zumwalt (collectively "Respondents"). 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 Recover Costs, S-09-020-12-SC01, against the Respondents on March 14, 2013. The Division alleged that from November 2006 through February 2008, Zumwalt raised a total of $518,000 by selling investments primarily to members of an investment club based in Port Orchard, Washington. The majority of investments were in the form of LLC units in Strategic I, LLC and Strategic IV, LLC. Investor funds were intended to be used to acquire and operate commercial or residential real estate properties. Although both offerings were eventually discontinued before the purchase of any properties, not all of the Strategic I, LLC investors received their principal back. Zumwalt also sold a partnership interest in his real estate brokerage business, SAAM Realty, LLC, to at least one investment club member. The Division further alleged that Respondents offered and sold unregistered securities, acted as unregistered broker-dealers or securities salespersons, and violated the anti-fraud provisions of the Securities Act of Washington. The Respondents neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act and to pay investigative costs of $2,500. The Respondents waived their right to a hearing and to judicial review of this matter.


SuperFix, LLC; Kenneth Kinnear - S-11-0688-13-SC02 - Statement of Charges

On July 3, 2013, 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 SuperFix, LLC and Kenneth Kinnear (“Respondents”). The Statement of Charges alleges that Respondents offered and sold over $160,000 of SuperFix, LLC membership interests. The Statement of Charges further alleges that Respondents offered and sold unregistered securities and that Kenneth Kinnear acted as an unregistered securities salesperson or broker-dealer in violation of the Securities Act of Washington. The Statement of Charges also alleges that Respondents violated the anti-fraud provisions of the Securities Act of Washington. The Securities Division intends to order Respondents to cease and desist from violating the Securities Act of Washington, and gives notice of its intent to impose a fine 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 May 23, 2014.


Showdown Partners, LLC; Express Entertainment, Inc.; Kenneth Kinnear; George Todd - S-11-0688-13-SC01 - Statement of Charges

On July 3, 2013, 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 Showdown Partners, LLC; Express Entertainment, Inc.; Kenneth Kinnear; and George Todd (“Respondents”). The Statement of Charges alleges that Respondents solicited over 100 prospective investors to invest in Showdown Partners, LLC membership units and sold over $5 million of these investments. The Statement of Charges further alleges that Respondents offered and sold unregistered securities and that Express Entertainment, Inc.; Kenneth Kinnear; and George Todd acted as unregistered securities salespersons or broker-dealers in violation of the Securities Act of Washington. The Statement of Charges also alleges that Respondents violated the anti-fraud provisions of the Securities Act of Washington. The Securities Division intends to order Respondents to cease and desist from violating the Securities Act of Washington, and gives notice of its intent to impose fines and charge costs. Respondents have a right to request a hearing on the Statement of Charges.

A Consent Order as to George Todd was entered on September 10, 2013.

A Consent Order was entered regarding this matter on May 23, 2014.


Pangean Energy, LLC; Bart Sweazea; Ray Valdez - S-13-1182-13-SC01 - Statement of Charges

On July 3, 2013, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Impose Fines and to Charges Costs (Statement of Charges) against Respondents Pangean Energy, LLC, Bart Sweazea, and Ray Valdez (collectively "the Respondents"). The Statement of Charges alleges that Respondents violated RCW 21.20.040 and RCW 21.20.140 when they offered or sold unregistered oil and gas investments to Washington State residents. Further, the Statement of Charges alleges that Respondents violated RCW 21.20.010, the anti-fraud provision of the Washington Securities Act, when they failed to disclose material information about the investment, including risks of the investment. The Securities Division intends to order the Respondents to cease and desist from violating the Securities Act of Washington, to impose fines, and to charge costs. The Respondents have the right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on September 20, 2013.


Seattle Business Associates, LLC; Hanbleceya Seattle Real Estate, LLC; Kerry Paulson; Elizabeth Browning - S-12-1041-13-CO01 - Consent Order

On July 2, 2013, the Securities Division entered into a Consent Order with Respondents, Seattle Business Associates, LLC (SBA), Hanbleceya Seattle Real Estate, LLC (HSRE), Kerry Paulson (Paulson), and Elizabeth Browning (Browning). The Consent Order alleges that Paulson and Browning raised $835,000 through the offer and sale of limited liability company interests in SBA and HSRE from twelve investors. The Consent order further alleges that Respondents violated the securities registration provision of the Securities Act of Washington. The Consent Order also alleges that Paulson and Browning violated the broker-dealer/salesperson registration provision of the Securities Act of Washington. Without admitting or denying the Securities Division’s allegations, Respondents each agreed to cease and desist from violating the Securities Act of Washington. Paulson paid a fine of $3,500 and paid investigative costs of $2,500. Browning paid a fine of $2,500 and paid investigative costs of $2,500. SBA and HSRE are jointly liable for a fine of $5,000 and investigative costs of $2,500, payment of which is deferred until investors have been repaid in full. Respondents each waived their right to a hearing and judicial review of the matter.


Money Now Funding, LLC - S-13-1198-13-SC01 - Statement of Charges

On June 26, 2013, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist (Statement of Charges) against Leary Darling, Maria Sebastiana Hobbs a/k/a Anna Hobbs, Vanessa Hobbs, Money Now Funding, LLC, US Doc Assist, LLC, and Legal Dox, LLC. The Statement of Charges alleges that the Respondents violated the Business Opportunity Fraud Act through their offer and sale of a Money Now Funding business opportunity to a Washington resident. The Statement of Charges further alleges that the Respondents violated the registration, disclosure document, and anti-fraud provision of Business Opportunity Fraud Act, and it also gives notice of the Securities Division’s intent to enter an Order to Cease and Desist. Respondents have a right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on August 2, 2013.


Discovery Tours LLC; Melody Miranda; Fidel Armando Miranda - S-09-448-12-SC01 - Statement of Charges

On June 10th, 2013, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, and to Charge Costs and to Impose Fines against Discovery Tours LLC, Melody Miranda and Fidel Armando Miranda, tour bus operators based in Chehalis, Washington. The Division alleges that from 2005 and 2009, Discovery Tours raised over $1.5 million through the offer and sale of investments that were referred to as “Growth Notes,” “Certificates,” “Growth Certificates,” “Expansion Notes,” and “Mortgage Notes” to more than 350 investors in Washington, many of whom are senior citizens. The Division further alleges that Respondents offered and sold unregistered securities, acted as unregistered broker-dealers or securities salespersons, and violated the anti-fraud provisions of the Securities Act of Washington. The Division ordered Respondents to cease and desist from violating the Securities Act of Washington. The Division 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 November 22, 2013.


Rafael Vasquez d/b/a Rafael Vasquez Investments & Securities L.L.C. - S-13-1155-13-SC01 - Statement of Charges

On June 10, 2013, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Impose a Fine, to Charge Costs, and to Deny Future Registrations (the “Statement of Charges”) against Rafael Vasquez d/b/a Rafael Vasquez Investments & Securities L.L.C. (“Vasquez”). The Statement of Charges alleges that Vasquez held himself out as an investment adviser while not registered as such, or exempt from such registration, in Washington. The Statement of Charges further alleges that, in doing so, Vasquez violated the section of the Washington Securities Act requiring registration of investment advisers. The Statement of Charges gives notice of the Securities Division’s intent to order Vasquez to cease, and desist, to impose a fine, to charge its investigative costs, and to deny any investment adviser registration and investment adviser representative registration that Vasquez may seek in the future.

A Final Order regarding this matter was entered on July 30, 2013.


J.K. Holdings I, Inc; Hillstrom Cabinets, Inc.; Jonathan Kniss; Laura Kniss - S-10-401-12-CO01 - Consent Order

On June 10, 2013, the Securities Division entered into a Consent Order with J.K. Holdings I, Inc. (“JKH”), Hillstrom Cabinets, Inc. (“HCI”), and Jonathan and Laura Kniss (collectively, “Respondents”). The Securities Division had previously entered a Statement of Charges against the Respondents alleging that Jonathan Kniss and JKH offered and sold securities to enable the purchase of HCI by Jonathan Kniss and JKH and that Respondents offered and sold securities several years later to keep HCI open as it struggled under Jonathan Kniss’s leadership. The Statement of Charges further alleged that, in doing so, Respondents violated the Securities Act of Washington’s securities registration and anti-fraud provisions and that Jonathan and Laura Kniss each violated the Act’s provision requiring registration of securities salespersons and broker-dealers. Without admitting or denying the Securities Division’s allegations, Respondents agreed to cease and desist from violating the Washington Securities Act and waived their right to a hearing and to judicial review of this matter.


Michael Gintz; David Gintz; Ronald Gintz; Erik Robbins; Gintz Group, LLC; 2681 Central Terrace, LLC; 705 East Republican, LLC; 1550 North Parkway, LLC; 755 Broadway, LLC; 1052 South 27th Street, LLC; 27th Street Station, LLC; Gintz Group Equity Fund, LLC; Gintz Group Development, LLC - S-11-0620-13-SC01 - Statement of Charges

On May 31, 2013, 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 Michael Gintz; David Gintz; Ronald Gintz (CRD #819831); Erik Robbins; Gintz Group, LLC; 2681 Central Terrace, LLC; 705 East Republican, LLC; 1550 North Parkway, LLC; 755 Broadway, LLC; 1052 South 27th Street, LLC; 27th Street Station, LLC; Gintz Group Equity Fund, LLC and Gintz Group Development, LLC (collectively “Respondents). The Securities Division alleged that Respondents violated RCW 21.20.010, RCW 21.20.040 and RCW 21.20.140 by offering and selling approximately $15,000,000 worth of unregistered securities to 91 investors. The Securities Division additionally alleged that Respondents made material misrepresentations and omissions in connection with the offer and sale of Respondents’ securities. The Statement of Charges gives notice of the Securities Division’s intent to enter an Order to Cease and Desist, to impose fines and to collect costs. Respondents have the right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on December 12, 2013.

A Consent Order as to Michael Gintz was entered on October 03, 2013.

A Consent Order as to Ronald Gintz was entered on August 15, 2013.


David Gintz; Joe Toner; John Griffith; Deb Townsend; Jenning Development, LLC; Jenning Investment One, LLC; Jenning Investment Two, LLC; Gintz & Toner, LLC - S-11-0620-13-SC02 - Statement of Charges

On May 31, 2013, 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 David Gintz; Joe Toner; John Griffith; Deb Townsend; Jenning Development, LLC; Jenning Investment One, LLC; Jenning Investment Two, LLC and Gintz & Toner, LLC (collectively “Respondents). The Securities Division alleged that Respondents violated RCW 21.20.010, RCW 21.20.040 and RCW 21.20.140 by offering and selling approximately $900,000 worth of unregistered securities to 24 investors. The Securities Division additionally alleged that Respondents made material misrepresentations and omissions in connection with the offer and sale of Respondents’ securities. The Statement of Charges gives notice of the Securities Division’s intent to enter an Order to Cease and Desist, to impose fines and to collect costs. Respondents have the right to request a hearing on the Statement of Charges.

A Consent Order as to Joe Toner was entered on February 5, 2014.

A Final Order as to John Griffith was entered on January 15, 2014.

A Consent Order was entered regarding this matter on December 12, 2013.

A Consent Order as to Deb Townsend was entered on September 17, 2013.


Mark Nuovo - S-12-1035-13-CO01 - Consent Order

On May 31, 2013, the Securities Division entered into a Consent Order with Mark Nuovo (“Nuovo”). The Securities Division had previously issued a Statement of Charges, S-12-1035-13-SC01, against Nuovo. The Securities Division alleged that Nuovo effected transactions in securities that were not offered or reviewed by his broker-dealer firm and off the regular books and records of his broker-dealer firm, failed to inform his broker-dealer firm of his outside business activities, and falsely filed Form U4s with the Washington State Securities Division. The Securities Division also alleged that Nuovo gave at least one Washington investor a profit projection without disclosing the material bases and assumptions underlying the projection. Nuovo agreed to cease and desist from violating the Securities Act of Washington and that any future securities registration applications filed by Nuovo will be denied by the Securities Division. Nuovo neither admitted nor denied the Securities Division’s allegations. Nuovo waived his right to a hearing and judicial review of this matter.


Bonita Kay Bell-Andersen; Bell-Andersen Financial Services, LLC: Quadrant Wealth Management, Inc. - S-11-0855-13-SC02 - Amended Statement of Charges

On May 22, 2013, the Securities Division entered an Amended Statement of Charges, Denial of Registration as to Quadrant Wealth Management, Inc., and Notice of Intent to Deny Future Registrations, Impose Fines and Charge Costs and to Enter Order to Cease and Desist (“Amended Statement of Charges”) against Respondents, Bonita Kay Bell-Andersen (“Bell-Andersen”), Bell-Andersen Financial Services, LLC (“BAFS”) and Quadrant Wealth Management, Inc. (“QWM”). The Securities Division alleged that Bell-Andersen and BAFS violated RCW 21.20.040(1), RCW 21.20.040(3), RCW 21.20.040(4) and RCW 21.20.350 by acting as an unregistered broker-dealer and/or securities salesperson, acting as an unregistered investment adviser, holding out as an investment adviser while unregistered and making a false filing with the Securities Administrator. The Securities Administrator denied QWM’s registration application to become an investment-adviser consistent with RCW 21.20.110 because Bell-Andersen is the sole director of QWM. The Securities Administrator amended a prior Statement of Charges entered on December 18, 2012, to include allegations that Bell-Andersen engaged in dishonest or unethical conduct in the securities industry by signing client names to forms requiring genuine client signatures. The Amended Statement of Charges gives notice of the Securities Division’s intent to enter an Order to Cease and Desist, to deny future registration applications filed by Bell-Andersen, to impose fines and to collect costs. Respondents have requested a hearing on the prior Statement of Charges in the same matter, and their requests will be effective as to this Amended Statement of Charges.


Bonita Kay Bell-Andersen; Bell-Andersen Financial Services, LLC; Quadrant Wealth Management, Inc; John P. Johnson - S-11-0855-13-CO01 - Consent Order

On May 21, 2013, the Securities Division entered into a consent order with John Johnson (“Johnson”) (CRD No. 2195650). The Securities Division alleged that Johnson, in connection with his role as a registered securities salesperson, engaged in dishonest and unethical practices in the securities industry. The Securities Division alleged that he shared confidential information with an unauthorized third party. The Securities Division also alleged that Johnson dealt with a third party concerning his customers’ securities accounts without written authorization from the customers in violation of his firm’s written supervisory policies. Without admitting or denying the Securities Division’s allegations, Johnson agreed to a censure, a $3,000 fine, and agreed to pay the costs of the Division’s investigation in the amount of $1,500. Johnson also agreed that, prior to any future registrations as a securities salesperson or investment advisor representative, Johnson’s sponsoring firm shall provide to the Securities Division a continuing education plan tailored to the allegations made by the Division. Johnson waived his right to an administrative hearing and judicial review of the matter.


Retirement Protection Services Wealth Management LLC; Gregg Alan Henderson - S-13-1210-13-SC01 - Statement of Charges

On May 17, 2013, the Securities Division entered a Statement of Charges and Notice of Intent to Revoke Registrations, Impose Fines, and Charge Costs (“Statement of Charges”) against Respondents Retirement Protection Services Wealth Management LLC (“RPSWM”) and Gregg Alan Henderson. The Statement of Charges alleged that Gregg Alan Henderson impersonated a client in an attempt to liquidate that client’s account, was the subject of an Order by the Washington Office of the Insurance Commissioner revoking his insurance producer license for violations of Washington insurance laws, filed false or misleading documents with the Securities Division, and failed to make required updates to RPSWM’s disclosure documents. The Statement of Charges further alleged that this conduct violated the Securities Act of Washington. The Statement of Charges gives notice of the Securities Division’s intent to order the revocation of RPSWM’s investment adviser and Gregg Alan Henderson’s investment adviser representative registrations, the denial of future registrations, the imposition of fines, and the charging of costs. Respondents have the right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on January 2, 2014.


Kevin George Healy; Domlex Destiny Five Limited Liability Company; Domlex Destiny Five Group Limited Liability Company - S-08-360-13-FO01 - Final Order

On May 13, 2013, the Securities Division entered a Final Order against Respondents, Kevin George Healy (“Healy), Domlex Destiny Five Limited Liability Company (“Domlex”), and Domlex Destiny Five Group Limited Liability Company (“Domlex Group”). The Securities Division had previously entered a Statement of Charges against Respondents. The Statement of Charges alleged that from at least 2006 until 2008, Respondents did business in Bellevue, Washington and that Healy offered and sold to at least ten Washington investors more than $3 million worth of promissory notes issued by Healy and his companies, Domlex and Domlex Group. The Final Order orders the Respondents to cease and desist from violating the Securities Act of Washington and to pay a fine. The Respondents have the right to request judicial review of the Final Order.


Clarence C. Young; Cautious, LLC; West Coast Financial, LLC; Safeguard Capital, LLC; Equity Interests, LLC; Be Well, LLC - S-11-0680-13-CO01 - Consent Order

On May 6, 2013, The Securities Division entered into a Consent Order with Clarence C. Young Jr. The Securities Division had previously issued a Statement of Charges, S-11-0680-12-SC01, against Clarence C. Young Jr. (Young); Cautious, LLC (Cautious); West Coast Financial, LLC (West Coast); Safeguard Capital, LLC (Safeguard); Equity Interests, LLC (Equity); and Be Well Today, LLC (Be Well) (collectively, Respondents). The Securities Division alleged that Young violated RCW 21.20.020 by engaging in acts which operated as a fraud upon those he advised. The Securities Division alleged that Young, Cautious, West Coast, Safeguard, and Equity violated RCW 21.20.010, the anti-fraud provision of the Securities Act of Washington. The Securities Division also alleged that Young, Cautious, West Coast, Safeguard, and Equity sold unregistered securities in violation of RCW 21.20.140. The Securities Division alleged that Young violated RCW 21.20.040 by acting as an unregistered broker-dealer and/or securities salesperson and by acting as an unregistered investment adviser. The Securities Division alleged that Be Well violated RCW 21.20.040 by acting as an unregistered broker-dealer. Without admitting or denying the Securities Division’s allegations, Respondents each agreed to cease and desist from violating the Washington Securities Act. Respondents each waived their right to a hearing and judicial review of the matter.


WA Real Estate Solutions, LLC; Kerwin Burton; Rosalyn Burton-Torres - S-09-466-12-CO01 – Consent Order

On April 19, 2013, the Securities Division entered into a Consent Order with Kerwin Burton, Rosalyn Burton-Torres, and WA Real Estate Solutions, LLC (collectively "Respondents"). The Securities Division had previously 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 on October 19, 2012. The Statement of Charges alleged that Respondents offered and sold an estimated $170,000 in unregistered promissory note investments to at least five investors in Washington. The Statement of Charges also alleged that Respondents also offered a variety of other investments through an offering document, mass emails, and websites. The Statement of Charges further alleged that Respondents offered unregistered securities and violated the anti-fraud provisions of the Securities Act of Washington, and that Respondents Kerwin Burton and Rosalyn Burton-Torres acted as unregistered broker-dealers or securities salespersons. In settling the matter, Respondents neither admitted nor denied the Securities Division’s allegations, but agreed to cease and desist from violating the Securities Act of Washington. The Consent Order requires Respondents to pay investigative costs of $500 and imposes a $500 fine against Respondents. Respondents waived their right to a hearing and judicial review of this matter.


Blue Chip Focus Fund, LP; Opportunities Fund, LP; Biotechnology Fund, LP; Sasquatch US Strategy Fund, LP f/k/a US Blue Chip Model, LP; Sasquatch Capital, LLC; Lyman Bruhn - S-11-0662-13-FO01 – Final Order

On April 19, 2013, the Securities Division entered a Final Order against Blue Chip Focus Fund, LP; Opportunities Fund, LP; Biotechnology Fund, LP; Sasquatch US Strategy Fund, LP f/k/a US Blue Chip Model, LP; Sasquatch Capital, LLC; and Lyman Bruhn (“Bruhn”) (collectively, “Respondents”). The Securities Division had previously entered a Statement of Charges against Respondents alleging that between approximately 1999 and 2004, Bruhn offered and sold at least $349,000 worth of limited partnership interests in the Respondent entities to at least seven Washington residents. The Statement of Charges further alleges that, in doing so, Respondents committed multiple violations of the Washington Securities Act (the “Act”). The Final Order orders the Respondents to cease and desist from violating the Act, imposes fines, and orders the Respondents to reimburse the Securities Division its investigative costs. The Respondents have a right to request judicial review of the Final Order.


The Institute For Financial Learning Group of Companies, Inc.; Strategic Metals, Inc., Merendon Mining Corporation, Ltd., Milowe A. Brost; Kristina J. Bass f/k/a Kristina J. Katayama and a/k/a Kristina J. Katayama Bass; Ronald R. Case; Warren L. Bosma; Ward K. Capstick - S-04-124-08-CO04 - Consent Order

On April 19, 2013, the Securities Division entered into a consent order with Kristina J. Bass f/k/a Kristina J. Katayama and a/k/a Kristina J. Katayama Bass. The Securities Division had previously issued a Statement of Charges, S-04-124-08-SC01, against Mrs. Bass f/k/a Kristina J. Katayama, The Institute For Financial Learning Group of Companies, Inc., Strategic Metals, Inc., Merendon Mining Corporation, Ltd., Milowe A. Brost, and others. The Securities Division had alleged that Respondent Kristina Bass violated the state securities registration, broker-dealer/salesperson registration and anti-fraud laws in connection with the offer and sale of promissory notes. Without admitting or denying the Securities Division’s allegations, Kristina Bass agreed to cease and desist from violating the securities registration, broker-dealer/salesperson registration and anti-fraud laws of the state Securities Act. Kristina Bass waived her right to a hearing and judicial review of the matter.


Champion Child, Inc. d/b/a "Stretch-n-Grow," Jill A. Manly, Robert E. Manly a/k/a Bob Manly and Caryn J. Burnier – S-11-0845-13-FO01 – Final Order

On April 9 2013, the Securities Division entered a Final Order against Respondents Champion Child, Inc. doing business as Stretch-N-Grow, a Florida corporation, Jill A. Manly, Robert E. Manly a/k/a Bob Manly, and Caryn J. Burnier. The Securities Division had previously entered a Statement of Charges against the Respondents alleging that they violated the registration and anti-fraud provisions of the state Franchise Act in connection with the offer and sale of a franchise to Washington State residents. The Final Order orders the Respondents to cease and desist from violating the Franchise Act. The Respondents have a right to seek judicial review of the Final Order.


PetroGates, Inc.; Davis Gates Smith – S-11-0755-13-FO01 – Final Order

On April 9, 2013, the Securities Division entered a Final Order against PetroGates, Inc. and Davis Gates Smith (collectively, “Respondents”). The Securities Division had previously entered a Statement of Charges against the Respondents alleging that the Respondents violated the anti-fraud provisions of the Securities Act of Washington when they offered and sold investments in oil and gas ventures to a Washington resident. The Final Order orders the Respondents to cease and desist from violating the Securities Act of Washington, to reimburse the Securities Division its investigative costs, and to pay a fine. The Respondents have a right to seek judicial review of the Final Order.


SpiritLiving Co. and Dennis Eugene Crumb – S-12-1087-13-CO01 – Consent Order

On April 4, 2013, the Securities Division entered into a Consent Order with Respondents, SpiritLiving Co. and Dennis Eugene Crumb. The Consent Order alleges that Respondents were in the business of offering and selling home and garden products through the Internet. The Consent Order alleges that Respondents each offered and sold $25,000 worth of stock in SpiritLiving Co. to a Washington investor in September 2008 without disclosing material information about the investment, including a prior default on promissory notes that were issued to a Colorado corporation. Without admitting or denying the Securities Division’s allegations, Respondents agreed to cease and desist from violating the anti-fraud provision of the Securities Act of Washington. Dennis Eugene Crumb also paid a fine of $2,500 and paid investigative costs of $1,000. Respondents each waived their right to a hearing and judicial review of the matter.


Gregory Pinneo and Yale Avenue Partners, LLC - S-10-047-12-CO01 - Consent Order

On April 4, 2013, the Securities Division entered into a Consent Order as to Gregory Pinneo (“Pinneo”) and Yale Avenue Partners, LLC ("Yale Avenue Partners") (collectively “Respondents”). The Consent Order alleges that from approximately December 2005 through October 2008, Pinneo raised approximately $4.5 million through the offer and sale of limited liability company interests in East Edgar Partners, LLC; Franklin Avenue Partners, LLC; Yale Avenue Partners; and 2344-2345 Franklin Twins, LLC to approximately 76 investors, the majority of whom were Washington residents. The Consent Order further alleges that Pinneo violated the securities registration and anti-fraud provisions of the Securities Act of Washington. The Consent Order also alleges that Yale Avenue Partners violated the securities registration provisions of the Securities Act of Washington. Without admitting or denying the Securities Division’s allegations, Respondents each agreed to cease and desist from violating the Securities Act of Washington. Pinneo paid a fine of $3,000 and paid investigative costs of $3,000. Respondents each waived their right to a hearing and judicial review of the matter.


Mark Nuovo – S-12-1035-13-SC01 – Statement of Charges

On March 29, 2013, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, Deny Future Registrations and to Impose Fines and Charge Costs (“Statement of Charges”) against Mark Nuovo (“Nuovo”). The Securities Division alleged that Nuovo effected transactions in securities that were not offered or reviewed by Euro and off the regular books and records of his broker-dealer firm, failed to inform his broker-dealer firm of his outside business activities in violation and falsely filed Form U4s with the Washington State Securities Division. The Securities Division also alleged that Nuovo gave at least one Washington investor a profit projection without disclosing the material bases and assumptions underlying the projection. The Securities Division intends to order Nuovo to cease and desist from violating the Securities Act of Washington, deny future securities registrations applications, impose fines, and charge costs. Nuovo has the right to request a hearing on the Statement of Charges.

A Consent Order as to Mark Nuovo was entered on May 31, 2013.


Cecilia Cabasco Sawyer – S-13-1154-13-SC01 – Statement of Charges

On March 29, 2013, the Securities Division entered a Statement of Charges and Notice of Intent to Enter an Order to Deny Future Registrations, to Impose Fines, and to Charge Costs (Statement of Charges) against Respondent, Cecilia Cabasco Sawyer, aka Cecilia Cabasco Villanueva (Sawyer). The Statement of Charges alleges that Sawyer forged documents in order to claim a client’s annuity death benefit, falsely opened a bank account under the client’s name, and deposited the death benefit funds into the account. It further alleges that Sawyer forged checks on the bank account and withdrew funds for her own benefit. The Statement of Charges alleges that Sawyer misrepresented the beneficiary and the value of the death benefit to a second client, forged a variable annuity application in the second client’s name, and forged the check used to purchase the annuity. The Statement of Charges alleges that such behavior is dishonest or unethical as described by WAC 460-22B-090, and it is grounds for a fine, costs, and denial of future registration applications pursuant to RCW 21.20.110(1)(g). The Statement of Charges also alleges that Sawyer’s actions violated FINRA Rule 2010, an ethical standard, that Sawyer was convicted of a felony of moral turpitude, and that Sawyer was the subject of an order revoking her insurance producer license for violating Washington insurance laws. The Securities Division intends to deny future securities registration applications, impose fines, and charge costs. Respondent has the right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on September 11, 2013.


Kathleen R. Bright - S-07-169-12-CO01 - Consent Order

On March 28, 2013, the Securities Division entered into a Consent Order, S-07-169-12-CO01, with Kathleen R. Bright. 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 Recover Costs, S-07-169-11-SC01, against Radix Marine, Inc., Kathleen R. Bright, and Brad M. Goodspeed (collectively “Respondents”) on August 21, 2012. Radix Marine, Inc., located in Yakima, Washington, primarily develops, manufactures, and/or markets marine vessels. The Division alleged that the Respondents raised a total of $244,900 by selling convertible promissory notes to at least 14 investors, including at least 7 Washington residents. The Division further alleged that the Respondents offered and sold unregistered securities and violated the anti-fraud provision of the Securities Act of Washington. Kathleen R. Bright neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act and to pay investigative costs of $1,000. Kathleen R. Bright waived her right to a hearing and to judicial review of this matter.


SearchPath International, Inc.; Pathfinder Search Partners of Cleveland, Inc. d/b/a SearchPath of Cleveland Uptown - S-12-1084-12-SC01 - Statement of Charges

On March 15, 2013, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist (Statement of Charges) against SearchPath International, Inc. and Pathfinder Search Partners of Cleveland, Inc. d/b/a SearchPath of Cleveland Uptown. (collectively, Respondents). The Statement of Charges alleges that Respondents offered and sold an unregistered franchise to a Washington resident and that it failed to provide the Washington resident with a franchise disclosure document. The Statement of Charges further alleges that Respondents violated RCW 19.100.170 because, in connection with the sale of a franchise, Respondents omitted a material fact. Respondents each have a right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on August 6, 2013.


Strategic I, LLC; Strategic IV, LLC; SAAM Realty, LLC; Edward R. Zumwalt - S-09-020-12-SC01 - Statement of Charges

On March 14, 2013, the Securities Division entered a Statement of Charges and Notice of Intent to Issue an Order to Cease and Desist, Impose Fines, and Recover Costs against Strategic I, LLC; Strategic IV, LLC; SAAM Realty, LLC; and Edward R. Zumwalt (collectively “Respondents”). The Division alleges that from November 2006 through February 2008, Zumwalt raised a total of $518,000 by selling investments primarily to members of an investment club based in Port Orchard, Washington. The majority of investments were in the form of LLC units in Strategic I, LLC and Strategic IV, LLC. Investor funds were intended to be used to acquire and operate commercial or residential real estate properties. Although both offerings were eventually discontinued before the purchase of any properties, not all of the Strategic I, LLC investors received their principal back. Zumwalt also sold a partnership interest in his real estate brokerage business, SAAM Realty, LLC, to at least one investment club member. The Division further alleges that Respondents offered and sold unregistered securities, acted as unregistered broker-dealers or securities salespersons, and violated the anti-fraud provisions of the Securities Act of Washington. The Division ordered Respondents to cease and desist from violating the Securities Act of Washington. The Division 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 July 9, 2013.


Hounds Mounds, Inc. d/b/a Poop 911 - S-13-1191-13-CO01 - Consent Order

On March 13, 2013, the Securities Division entered into a consent order with Hounds Mounds, Inc. d/b/a Poop 911, of Dallas, Texas. In the consent order, the Securities Division alleged that the Respondent violated the registration and disclosure document provisions of the state Franchise Act in connection with the offer and/or sale of its pet waste removal franchise to Washington residents. Without admitting or denying the Securities Division’s allegations, Respondent agreed to cease and desist from violating the registration and disclosure document provisions of the state Franchise Act. Respondent further agreed to reimburse the Securities Division $875 for its costs of investigation. Respondent waived its right to a hearing and judicial review of the matter.


Byron Workman - S-10-442-13-FO03 - Final Order

On March 11, 2013, the Securities Division entered a Final Order against Byron Workman ("Workman"). The Securities Division had previously entered a Statement of Charges against Workman and others on May 27, 2011. The Statement of Charges alleged that Workman offered and sold a promissory note to a Washington couple. The Statement of Charges further alleged that Workman violated the registration of securities provision of the Securities Act of Washington (the "Act"), the Act’s registration of securities broker-dealers and salespersons provision, and the Act’s anti-fraud provision. The Final Order orders Workman to cease and desist from violations of the Securities Act of Washington. Workman has the right to request judicial review of the Final Order.


PetroGates, Inc.; Davis Gates Smith – S-11-0755-12-SC01 – Statement of Charges

On March 11, 2013, the Securities Division entered a Statement of Charges and Notice of Intent to Order to Cease and Desist, to Charge Costs, and to Impose Fines against PetroGates, Inc. and Davis Gates Smith (collectively “Respondents”). The Statement of Charges alleges that the Respondents violated the anti-fraud provisions of the Securities Act of Washington when they offered and sold investments in oil and gas ventures to a Washington resident. The Securities Division intends to order Respondents to cease and desist from violating the Securities Act of Washington, and gives notice of its intent to impose fines and charge costs. Respondents have a right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on April 9, 2013.


JFB Capital LLC; Jason F. Bond - S-12-0958-13-TO02 - Summary Order

On March 11, 2013, the Securities Division entered a Summary Order to Suspend Investment Adviser and Investment Adviser Representative Registrations and Statement of Charges and Notice of Intent to Revoke Registrations, to Impose Fines, and to Charge Costs (“the Order”) against JFB Capital LLC and Jason F. Bond. The Order alleges that JFB Capital LLC, a registered investment adviser, and Jason F. Bond, JFB Capital LLC’s investment adviser representative, have willfully violated the Securities Act of Washington and Consent Order S-12-0958-12-CO01 by failing to maintain JFB Capital LLC’s minimum financial requirement and by failing to timely notify the Securities Division of JFB Capital, LLC’s inability to meet its minimum financial requirement. The Securities Division orders the suspension of JFB Capital LLC’s investment adviser and Jason Bond’s investment adviser representative registrations, and gives notice of the Securities Division’s intent to revoke those registrations, to impose fines, and to charge costs. Respondents have the right to request a hearing on the Order.

A Consent Order was entered regarding this matter on October 18, 2013.


David Patrick Thomas - S-12-0974-13-SC01 - Statement of Charges

On March 11, 2013, the Securities Division entered a Statement of Charges and Notice of Intent to Enter an Order to Cease and Desist, to Deny Future Registrations, to Impose a Fine, and to Charge Costs (“Statement of Charges”) against Respondent, David Patrick Thomas (“Thomas”). The Statement of Charges alleges that Thomas, who was formerly a registered securities salesperson in Bellingham, Washington, offered and sold more than $435,000 worth of securities to Washington investors. The Statement of Charges alleges that Thomas failed to disclose to investors that he did not have approval from his registered securities broker-dealer to offer or sell the investments and that he misrepresented or failed to disclose material information about the investments, including the risks of the investments. The Securities Division intends to order the Respondent to cease and desist from violating the Securities Act of Washington, deny future securities registration applications, impose a fine, and charge costs. Respondent has the right to request a hearing on the Statement of Charges.


SpiritLiving Co. and Dennis Eugene Crumb - S-12-1087-13-SC01 - Statement of Charges

On February 26, 2013, the Securities Division entered a Statement of Charges and Notice of Intent to Enter an Order to Cease and Desist, to Impose a Fine, and to Charge Costs (“Statement of Charges”) against Respondents, SpiritLiving Co. and Dennis Eugene Crumb. The Statement of Charges alleges that Respondents were in the business of offering and selling home and garden products through the Internet. The Statement of Charges alleges that Respondents each offered and sold $25,000 worth of stock in SpiritLiving Co. to a Washington investor in September 2008 without disclosing material information about the investment, including a prior default on promissory notes that were issued to a Colorado corporation. The Statement of Charges gives notice of the Securities Division’s intent to enter an order to cease and desist from violating the Securities Act of Washington, to impose a fine of $2,500, and to charge investigative costs of $1,000. Respondents each have the right to request a hearing on the Statement of Charges.

A Consent Order regarding this matter was entered on April 4, 2013.


Nutrition Without Borders, LLC dba H.U.M.A.N. Healthy Vending; Sean Kelly - S-12-1079-13-SC01 - Statement of Charges

On February 22, 2013, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist (“Statement of Charges”) against Nutrition Without Borders, LLC dba H.U.M.A.N. Healthy Vending and Sean Kelly (“Respondents”). In the Statement of Charges, the Division alleged that Respondents sold an unregistered vending machine business opportunity in violation of the Business Opportunity Fraud Act. The Division alleged that Respondents violated the registration, disclosure document, and anti-fraud provisions of the Business Opportunity Fraud Act. Respondents have a right to a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on October 11, 2013.


Chadwick B. King and Sarah Louthan a/k/a Cerah Bennett - S-12-0994-12-SC01 - Statement of Charges

On February 22, 2013, 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 Chadwick B. King (King) and Sarah Louthan a/k/a Cerah Bennett (Louthan). The Statement of Charges alleges that King and Louthan violated the registration and anti-fraud provisions of the Securities Act of Washington by making material misrepresentations and omissions in connection with the offer and sale of their securities. The Securities Division intends to order the Respondents to cease and desist from violating the Securities Act of Washington and gives notice of its intent to impose a fine and to charge costs. Respondents each have a right to request a hearing on the Statement of Charges.


ZAGG, Inc.; ZAGG Retail, Inc. - S-12-1111-12-CO01 - Consent Order

On February 22, 2013, the Securities Division entered into a Consent Order with ZAGG, Inc. and ZAGG Retail, Inc. In the Consent Order, the Securities Division alleged that ZAGG, Inc. sold unregistered franchises in the state of Washington, and that it failed to provide franchisees with a Franchise Disclosure Document. It also alleged that ZAGG Retail, Inc. failed to disclose the presence of Washington franchisees in its franchise registration application. The Consent Order alleged that this conduct by ZAGG, Inc. and ZAGG Retail, Inc. violated the Franchise Investment Protection Act of Washington. Without admitting or denying the allegations, ZAGG, Inc. and ZAGG Retail, Inc. agreed to cease and desist from violating the Franchise Investment Protection Act. Respondents further agreed to reimburse the Securities Division $2,650 for its costs of investigation. Respondents waived their right to a hearing and judicial review of the matter.


Blue Chip Focus Fund, LP; Opportunities Fund, LP; Biotechnology Fund, LP; Sasquatch US Strategy Fund, LP f/k/a US Blue Chip Model, LP; Sasquatch Capital, LLC; Lyman Bruhn - S-11-0662-12-SC01 - Statement of Charges

On February 8, 2013, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Impose Fines, and to Recover Costs (the “Statement of Charges”) against Blue Chip Focus Fund, LP; Opportunities Fund, LP; Biotechnology Fund, LP; Sasquatch US Strategy Fund, LP f/k/a US Blue Chip Model, LP; Sasquatch Capital, LLC; and Lyman Bruhn (“Bruhn”) (collectively, “Respondents”). The Statement of Charges alleges that between approximately 1999 and 2004, Bruhn offered and sold at least $349,000 worth of limited partnership interests in the Respondent entities to at least seven Washington residents. The Statement of Charges further alleges that, in doing so, Respondents committed multiple violations of the Washington Securities Act (the “Act”). The Statement of Charges gives notice of the Division’s intent to order the Respondents to cease and desist from violating the Act, to impose fines, and to recover costs. The Respondents have a right to request a hearing on the Statement of Charges.

A Final Order regarding this matter was entered on April 19, 2013.


Yofast, LP; David Warren a/k/a David Apperson a/k/a Hans W. Schnauber - S-09-449-13-FO01 - Final Order

On February 8, 2013, the Securities Division entered a Final Order against Yofast, LP and David Warren, a/k/a David Apperson, a/k/a Hans W. Schnauber (“Warren”) (collectively, “Respondents”). The Securities Division had previously entered a Statement of Charges against the Respondents alleging that Respondents offered and sold limited partnership interests to at least nine Washington residents. The Statement of Charges further alleged that Respondents violated the registration of securities and anti-fraud provisions of the Washington Securities Act (the “Act”), and that Warren violated the Act’s registration of securities broker-dealers and salespersons provision. The Final Order orders the Respondents to cease and desist from violations of the Securities Act of Washington, to reimburse the Securities Division its investigative costs, and to pay a fine. The Respondents have a right to seek judicial review of the Final Order.


Joseph A. Untalan, Steven D. Jackson, Genesis Holdings Group, Inc., and Phoenix Development Group, Inc. – S-11-0826-13-FO01 – Final Order

On February 6, 2013, the Securities Division entered a Final Order against Respondents, Joseph A. Untalan (“Untalan”), Steven D. Jackson (“Jackson”), Genesis Holdings Group, Inc. (“Genesis”) and Phoenix Development Group, Inc. (“Phoenix”). The Securities Division had previously entered a Statement of Charges against Respondents on November 7, 2012. The Statement of Charges alleged that Respondents violated RCW 21.20.010, RCW 21.20.040 and RCW 21.20.140 by offering and selling approximately $130,000 worth of unregistered securities to four Washington State residents. The Securities Division additionally alleged that Respondents made material misrepresentations and omissions in connection with the offer and sale of Respondents’ securities. The Final Order orders Respondents to cease and desist from violations of the Securities act of Washington and orders Untalan and Jackson to each pay a fine and to reimburse the Securities Division its investigation costs. Respondents have the right to request judicial review of the Final Order.


Settle, Dustin Lee - S-12-1127-12-SC01 - Statement of Charges

On February 1, 2013, 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. The Statement of Charges alleges that Dustin Lee Settle (Respondent) filed six Form U4 disclosure amendments with the Securities Division that falsely answered and/or failed to disclose at least five financial compromises, a federal tax lien, two felony charges, and/or a felony conviction. It alleges that, by filing an amendment to his Form U4 that contained misleading information, Settle made a false filing with the Securities Division in violation of RCW 21.20.350. The Statement of Charges alleges that Settle had an obligation under WAC 460-22B-060 to update his Form U4 within 30 days of any event that would make his Form U4 inaccurate. The Statement of Charges further alleges that Settle failed to comply with three FINRA rules and engaged in dishonest or unethical practices as defined by WAC 460-22B-090(19) and RCW 21.20.110(1)(g). The Statement of Charges also alleges that Settle was suspended by FINRA, and that Settle’s felony conviction involved moral turpitude. The Securities Division intends to order the Respondent to cease and desist from violating the Securities Act of Washington, deny future securities registrations applications, impose fines, and charge costs. Respondent has the right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on October 30, 2013.


James Wynstra - S-09-046-12-CO01 – Consent Order

On January 30, 2013, the Securities Division entered into a Consent Order with James Wynstra. The Securities Division had previously issued a Statement of Charges and Notice of Intent to Enter an Order to Cease and Desist, Impose Fines, and Recover Costs (“Statement of Charges”) against James Wynstra; Rita Lahman; Homestead Northwest, Inc.; Homestead NW Development Company; Homestar Northwest LLC; Great Links Resort LLC; Pro Bay LLC; and Sumas Mountain Village, Inc. (collectively Respondents”) on March 29, 2011. The Statement of Charges alleged that Respondents offered and sold an estimated $121,000,000 in unregistered real estate investments to at least 350 investors in Washington. The investments typically were promissory notes offering 8 to 10% interest and purportedly backed by a deed of trust on real estate. The Securities Division alleged that Respondents offered unregistered securities, acted as unregistered broker-dealers or securities salespersons, and violated the anti-fraud provisions of the Securities Act of Washington. In settling the matter, Respondent James Wynstra neither admitted nor denied the Securities Division’s allegations, but agreed to cease and desist from violating the Securities Act. The Consent Order requires Wynstra to pay investigative costs of $5,000. In addition, the Consent Order imposes a $100,000 fine against Wynstra, the payment of which is deferred until investors have been repaid in full. Wynstra waived his right to a hearing and judicial review of this matter.


Dinotech Corporation; Ruby Knighton - S-12-0906-13-FO01 - Final Order

On January 30, 2013, the Securities Division entered a Final Order against Respondents, Ruby Knighton (“Knighton”) and Dinotech Corporation (“Dinotech”). The Securities Division had previously issued a Statement of Charges against Respondents, Knighton and Dinotech, on November 7, 2012. The Statement of Charges alleged that Respondents violated RCW 21.20.010, RCW 21.20.040 and RCW 21.20.140 by offering and selling $20,000 worth of unregistered stock to a Washington investor in connection with an oil and gas scheme. The Securities Division additionally alleged that Respondents made material misrepresentations and omissions in connection with the offer and sale of Respondents’ securities. The Final Order orders Respondents to cease and desist from violations of the Securities Act of Washington and orders Respondents to pay a fine. Respondents have the right to request judicial review of the Final Order.


Rita Lahman - S-09-046-12-CO03 – Consent Order

On January 29, 2013, the Securities Division entered into a Consent Order with Rita Lahman. The Securities Division had previously issued a Statement of Charges and Notice of Intent to Enter an Order to Cease and Desist, Impose Fines, and Recover Costs (“Statement of Charges”) against James Wynstra; Rita Lahman; Homestead Northwest, Inc.; Homestead NW Development Company; Homestar Northwest LLC; Great Links Resort LLC; Pro Bay LLC; and Sumas Mountain Village, Inc. (collectively “Respondents”) on March 29, 2011. The Statement of Charges alleged that Respondents offered and sold an estimated $121,000,000 in unregistered real estate investments to at least 350 investors in Washington. The investments typically were promissory notes offering 8 to 10% interest and purportedly backed by a deed of trust on real estate. The Securities Division alleged that Respondents offered unregistered securities, acted as unregistered broker-dealers or securities salespersons, and violated the anti-fraud provisions of the Securities Act of Washington. In settling the matter, Respondent Rita Lahman neither admitted nor denied the Securities Division’s allegations, but agreed to cease and desist from violating the Securities Act. Lahman further agreed to pay a fine of $2,500. Lahman waived her right to a hearing and judicial review of this matter.


Petra Alluis dba Global Asset Research and Recovery - S-11-0692-12-SC01 - Statement of Charges

On January 23, 2013, 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 Petra Alluis dba Global Asset Research and Recovery (“Respondent”). The Statement of Charges alleges that Respondent offered and sold at least $25,000 in unregistered investment agreements to investors in Washington and other states. The Statement of Charges further alleges that Respondent violated the anti-fraud and registration provisions of the Securities Act of Washington. The Securities Division intends to order Respondents to cease and desist from violating the Securities Act of Washington, and gave notice of its intent to impose a fine and charge costs. Respondent has a right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on February 12, 2014.


Clarence C. Young Jr.; Cautious, LLC; West Coast Financial, LLC; Safeguard Capital, LLC; Equity Interests, LLC; and Be Well Today, LLC - S-11-0680-12-SC01 - Statement of Charges

On January 22, 2013, 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 Clarence C. Young Jr. (Young); Cautious, LLC (Cautious); West Coast Financial, LLC (West Coast); Safeguard Capital, LLC (Safeguard); Equity Interests, LLC (EI); and Be Well Today, LLC (Be Well) (collectively, Respondents). The Securities Division alleged that Young created and managed four pooled investment vehicles, Cautious, West Coast, Safeguard, and EI, through which he raised approximately $7,441,132 from investors through the sale of LLC membership interests. The Securities Division alleged that Young had control over the LLC pooled funds and invested the LLC pooled funds in larger trading programs of his choosing. The Securities Division further alleged that each trading program that Young chose was later investigated and helped shut-down by either the U.S. Securities and Exchange Commission or the U.S. Commodity Futures Trading Commission due to fraud. The Securities Division alleged that Young violated RCW 21.20.020 by engaging in acts which operated as a fraud upon those he advised when he, among other allegations, spent investor funds on his family-owned winery without ever informing investors. The Securities Division alleged that Young, Cautious, West Coast, Safeguard, and Equity violated RCW 21.20.010, the anti-fraud provision of the Securities Act of Washington. The Securities Division also alleged that Young, Cautious, West Coast, Safeguard, and Equity sold unregistered securities in violation of RCW 21.20.140. The Securities Division alleged that Young violated RCW 21.20.040 by acting as an unregistered broker-dealer and/or securities salesperson and acting as an unregistered investment adviser. The Securities Division alleged that Be Well violated RCW 21.20.040 by acting as an unregistered broker-dealer. The Statement of Charges gives notice to Respondents of the Securities Division’s intent to enter an order to cease and desist from violating the Securities Act of Washington, to impose fines, and to charge costs. Respondents have a right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on May 6, 2013.


David Lyn Lenihan; AllianceCapital Asset Management, LLC; Crown Preferred Capital, LLC; The UltraSharpe Fund, LP; Noah James Aulwes; and James Bernard Kayser - S-09-507-12-SCO1 - Statement of Charges

On January 11, 2013, 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 David Lyn Lenihan (“Lenihan”); AllianceCapital Asset Management, LLC (“AllianceCapital”); Crown Preferred Capital, LLC (“Crown Preferred”); The UltraSharpe Fund, LP (“UltraSharpe”); Noah James Aulwes (“Aulwes”); and James Bernard Kayser (“Kayser”) (Collectively “Respondents”). The Statement of Charges alleges that Lenihan created and managed two pooled investment vehicles, Crown Preferred and UltraSharpe, through which he raised approximately $6.8 million from investors through the sale of LLC or partnership interests. Both pooled investment vehicles purportedly involved Lenihan utilizing trading algorithms to determine when to buy and sell securities, with investors receiving a percentage of any profits from the trades. The Statement of Charges alleges that Crown Preferred, Lenihan, Aulwes, and Kayser sold unregistered securities and that they each violated RCW 21.20.010, the anti-fraud provision of the Securities Act of Washington when they sold interests in Crown Preferred. The Statement of Charges further alleges that UltraSharpe, Lenihan, and Aulwes violated RCW 21.20.010 when they sold interests in UltraSharpe. The Statement of Charges also alleges that Lenihan and AllianceCapital violated RCW 21.20.030(1) by entering into performance-based compensation arrangements with clients which did not qualify for an exemption. The Statement of Charges further alleges that Lenihan and AllianceCapital violated RCW 21.20.020, the investment adviser anti-fraud provision of the Securities Act of Washington. The Statement of Charges further alleges that Lenihan and AllianceCapital made false statements in Form ADV amendments filed with the Securities Director. The Securities Division intends to order Respondents to cease and desist from violating the Securities Act of Washington, and gives notice of its intent to deny future registrations, impose fines, and charge costs. Respondents have a right to request a hearing on the Statement of Charges.


William Spencer Howard III - S-09-154-12-CO01 - Consent Order

On January 11, 2013, the Securities Division entered into a Consent Order with William Spencer Howard III. The Securities Division had previously entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, Deny Future Registrations, Impose Fines, and Recover Costs against the Respondents William Spencer Howard III and Raymond Francis Purdon on March 1, 2011. The Securities Division alleged that while a Washington resident was Respondent Howard’s customer at GunnAllen Financial, Inc., Respondent Howard and/or his colleague Respondent Purdon solicited the resident to invest a total of $443,504 in two stock investments. The Securities Division alleged that in offering and selling the investments, Respondent Howard and/or Respondent Purdon violated the anti-fraud provision of the Securities Act of Washington by making misrepresentations and omissions of material facts, and engaged in dishonest or unethical practices by effecting securities transactions not recorded on the regular books and records of the broker-dealer which they represented. The Securities Division further alleged that in offering and selling the investments, Respondent Howard engaged in dishonest or unethical practices by recommending an unsuitable investment, marking an order ticket as unsolicited when in fact the transaction was solicited, and by forging the resident’s signature. Respondent Howard neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act. Respondent Howard further agreed to not apply for future securities licenses in the state of Washington. Respondent Howard waived his right to a hearing and to judicial review of this matter.


Champion Child, Inc. d/b/a “Stretch-n-Grow,” Jill A. Manly, Robert “Bob” Manly and Caryn J. Burnier - S-11-0845-12-SC01 - Statement of Charges

On January 7, 2013, the Securities Division entered a Statement of Charges against Respondents Champion Child, Inc. doing business as Stretch-N-Grow, a Florida corporation, Jill A. and Robert “Bob” E. Manly, and Caryn J. Burnier. The Securities Division alleged that the Respondents violated the registration and anti-fraud provisions of the state Franchise Act in connection with the offer and sale of a franchise to Washington State residents. The Securities Division intends to order the Respondents to cease and desist from violating the Franchise Act.

A Final Order was entered regarding this matter on April 9, 2013.

DFI