Washington State Department of Financial Institutions

2014 Administrative Orders

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Armadillo Energy, Inc.; Paul Schuett; Doug DeBoer; James Linde; and Bradley Belschner – S-13-1261-14-FO01 – Final Order

On April 3, 2014, the Securities Division entered a Final Order as to Armadillo Energy, Inc., Paul Schuett, and Bradley Belschner.

The Securities Division had previously entered a Statement of Charges against Armadillo Energy, Inc., Paul Schuett, Doug DeBoer, James Linde, and Bradley Belschner alleging that the Respondents violated the Securities Act of Washington in the process of raising money to operate an oil lease in Oklahoma.

The Final Order orders Armadillo Energy, Inc., Paul Schuett, and Bradley Belschner to cease and desist from violating the registration and anti-fraud provisions of the Securities Act of Washington, and it orders Aramdillo Energy, Inc. and Paul Schuett to pay fines and costs. Armadillo Energy, Inc., Paul Schuett, and Bradley Belschner have the right to request judicial review of the Final Order.


Donald A. Kernan – S-13-1332-14-FO01 – Final Order

On March 28, 2014, the Securities Division entered a Final Order against Donald Alan Kernan, Jr. (“Kernan”), and Donald Kernan, LLC f/k/a DreamTopia (“DreamTopia”) (collectively, “Respondents”). The Division previously entered a Statement of Charges against Respondents that alleged that Kernan obtained a $21,000 investment from a Washington resident after promising to add the Washington resident’s funds to Kernan’s account with Safe Deposit, S.A., a Panamanian corporation purporting to engage in speculative stock trading. The Statement of Charges also alleged that Kernan offered the Washington resident an investment in DreamTopia. In addition, the Statement of Charges alleged that Respondents violated the registration of securities and anti-fraud provisions of the Securities Act of Washington, and that Kernan acted as an unregistered securities salesperson in violation of the Act. The Final Order orders the Respondents to cease and desist from violating the Securities Act of Washington, to pay a fine, and to reimburse the Division’s costs. The Respondents have a right to request judicial review of the Final Order.


Jill Jensen-Ames – S-09-133-10-CO02 – Consent Order

On March 25, 2014, the Securities Division entered into a Consent Order with Jill Jensen Ames. The Securities Division had previously entered 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 Laguna S.A., Jill Jensen Ames, Katherine Swanberg, and Jeff Finch (collectively “Respondents”) on December 23, 2009. The Statement of Charges alleged that Respondents raised $820,000 by offering an investment contract involving land in Nicaragua to 15 investors, most of whom were Washington residents. 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, Respondent Ames neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act. Respondent Ames agreed to pay a fine of $5,000. Respondent Swanberg waived her right to a hearing and judicial review of the matter.


Sanuwave Health, Inc. – S-13-1399-14-CO01 - Consent Order

On March 13, 2014, The Securities Division entered into a Consent Order with Sanuwave Health, Inc. (Sanuwave). In the Consent Order, the Securities Division alleged that Sanuwave violated the registration provision of the Securities Act of Washington (the Act). Without admitting or denying the Securities Division’s allegations, Sanuwave agreed to cease and desist from violating the registration provision of the Act. Sanuwave further agreed to pay a fine of $1,000 and investigative costs of $500. Sanuwave waived its right to a hearing and judicial review of this matter.


Frederick Allan Bieber - S-11-0596-14-FO01 - Final Order

On March 10, 2014, the Securities Division entered a Final Order to Deny Future Registrations, Impose Fines, and Charge Costs against Frederick Allan Bieber (“Respondent”). The Division previously entered a Statement of Charges and Notice of Intent to Issue an Order to Deny Future Registrations, Impose Fines, and Charge Costs on January 7, 2014. The Respondent was formerly employed as a securities salesperson with KMS Financial Services, Inc. (“KMS”) and later Pacific West Securities, Inc. (“Pacific West”). While employed at KMS, the Respondent entered into a personal financial transaction with a customer and arranged loans for and between customers. When the Respondent was later employed with Pacific West, he did not provide prompt written notice to his firm when he received compensation from an outside business activity. The Respondent also made material misstatements to his firm on annual compliance questionnaires regarding the outside compensation he received. The Respondent engaged in dishonest and unethical practices in the securities business. The Division ordered that any future securities registration applications of the Respondent shall be denied. The Division also orders the Respondent to pay a fine of $20,000 and costs of $5,000. The Respondent has a right to request judicial review of this matter.


Envision Retirement LLC; Stephen J. Barrett - S-13-1167-13-CO01 - Consent Order

On March 10, 2014, the Securities Division entered into a Consent Order with Envision Retirement, LLC (“Envision”), and Stephen J. Barrett (“Barrett”) (collectively, “Respondents”). The Division had previously entered a Statement of Charges against Respondents and others alleging multiple violations of the Securities Act of Washington (the “Act”). Without admitting or denying the contents of the Statement of Charges, Respondents agreed to cease and desist from all violations of the Act and to reimburse the Securities Division $1,500 for investigative costs. The Consent Order also revoked Envision’s investment adviser registration and Barrett’s investment adviser representative registration. In settling, Respondents waived their rights to an administrative hearing and to judicial review of this matter.


Cirrus Partners, Inc.; MRG International, Inc. – S-13-1167-14-FO01 – Final Order

On March 5, 2014, the Securities Division entered into a Final Order against Cirrus Partners, Inc. and MRG International, Inc. (collectively, “Respondents”). The Division had previously entered a Statement of Charges against Respondents and others alleging multiple violations of the Securities Act of Washington (the “Act”). Respondents each failed to request an administrative hearing on the Statement of Charges within twenty days of being served. The Final Order orders Respondents to cease and desist from all violations of the Act and orders each Respondent to pay a fine of $10,000. Respondents have the right to judicial review of the Final Order.


Northwest Growers Association (Harrison) – S-13-1291-14-CO03 - Consent Order

On March 3, 2014, the Securities Division entered into a Consent Order with James Harrison. The Securities Division had previously entered a Statement of Charges against James Harrison on January 21, 2014. The Statement of Charges alleged that James Harrison 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, James Harrison agreed to cease and desist from violating the Securities Act of Washington and to pay a fine of $1,000 and investigative costs of $1,000. James Harrison waived his right to a hearing and judicial review of this matter.


Northwest Growers Association; Charles Feick; William Moore; James Harrison – S-13-1291-14-CO02 – Consent Order

On February 26, 2014, the Securities Division entered into a Consent Order with William Moore. The Securities Division had previously entered a Statement of Charges against William Moore on January 21, 2014. The Statement of Charges alleged that William Moore 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, William Moore agreed to cease and desist from violating the Securities Act of Washington and to pay a fine of $1,000 and investigative costs of $1,000. William Moore waived his right to a hearing and judicial review of this matter.


Armadillo Energy, Inc.; Paul Schuett; Doug DeBoer; James Linde; and Bradley Belschner – S-13-1261-13-SC01 – Statement of Charges

On February 24, 2014, 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 against Respondents Armadillo Energy, Inc., Paul Schuett, Doug DeBoer, James Linde, and Bradley Belschner.

The Statement of Charges alleges that Armadillo Energy, Inc. solicited Armadillo Energy Partnership Agreements to raise funds to operate an oil lease in Oklahoma. The Statement of Charges further alleges that in the course of soliciting these partnership agreements, the Respondents collectively misrepresented or failed to disclose material information to Armadillo Energy investors. Furthermore, the Statement of Charges alleges that Respondents Paul Schuett, Doug DeBoer, James Linde, and Bradley Belschner each violated the registration provision of the Securities Act of Washington in connection with their sale of Armadillo Energy Partnership Agreements.

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

A Final Order was entered regarding this matter on April 3, 2014.


Adams Financial Concepts, LLC and Alexander Michael Adams - S-13-1221-14-CO01 - Consent Order

On February 21, 2014, the Securities Division entered into a Consent Order with Respondents, Adams Financial Concepts, LLC (“AFC”), a registered investment adviser in Seattle, Washington, and Alexander Michael Adams (“Adams”), a registered investment adviser representative. The Securities Division alleged that AFC was the managing member of a hedge fund with four Washington limited partners who invested a total of approximately $2 million. The Securities Division alleged that when offering and selling the limited partnership interests and when purchasing investments for the hedge fund, Respondents failed to disclose material information to the investors. Without admitting or denying the allegations, Respondents agreed to pay a fine of $10,000, to pay investigative costs of $5,000, and agreed that Respondents would not have custody of any client funds or securities for a period of ten years from the date of the Consent Order. Respondents each waived their right to a hearing and to judicial review of this matter.


Gulftex Operating Inc - S-13-1274-14-SC01 - Statement of Charges

On February 21, 2014, 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 Gulftex Operating, Inc., Frenchtown Acres, LLC, Timothy P. Burroughs, and Tim Neeley (“Respondents”). The Statement of Charges alleges that Respondents violated RCW 21.20.140 and RCW 21.20.040 when they offered and sold $540,000 of unregistered oil and gas investments to Washington residents. Further, the Statement of Charges alleges that Respondents violated RCW 21.20.010, the anti-fraud provision of the Washington Securities Act. The Securities Division intends to order Respondents to each 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.


Charles Feick ; Northwest Growers Association, Inc - S-13-1291-14-CO01 – Consent Order

On February 14, 2014, the Securities Division entered into a Consent Order with Charles Feick and Northwest Growers Association, Inc. The Securities Division had previously entered a Statement of Charges against Charles Feick and Northwest Growers Association, Inc. on January 21, 2014. The Statement of Charges alleged that Charles Feick and Northwest Growers Association, Inc. violated RCW 21.20.010 and RCW 21.20.140, and that Charles Feick also violated RCW 21.20.040, in connection with the offer and sale of unregistered securities. Without admitting or denying the Securities Division’s allegations, Charles Feick and Northwest Growers Association, Inc. each agreed to cease and desist from violating the Securities Act of Washington and to each pay a fine of $1,000 and investigative costs of $1,000. Charles Feick and Northwest Growers Association, Inc. waived their right to a hearing and judicial review of this matter.


Donald Alan Kernan - S-13-1332-14-SC01 - Statement of Charges

On February 12, 2014, 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 (the “Statement of Charges”) against Donald Alan Kernan, Jr. (“Kernan”), and Donald Kernan, LLC f/k/a DreamTopia (“DreamTopia”) (collectively, “Respondents”). The Statement of Charges alleges that Kernan obtained a $21,000 investment from a Washington resident after promising to add the Washington resident’s funds to Kernan’s account with Safe Deposit, S.A., a Panamanian corporation purporting to engage in speculative stock trading. The Statement of Charges also alleges that Kernan offered the Washington resident an investment in DreamTopia. In addition, the Statement of Charges alleges that Respondents violated the registration of securities and anti-fraud provisions of the Securities Act of Washington, and that Kernan acted as an unregistered securities salesperson in violation of the Act. 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 recover costs. The Respondents have a right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on March 28, 2014.


Lakemont Commercial Consulting, LLC; Larrick Holdings LLC; and Larry F. Allen - S-12-1042-14-FO02 - Final Order

On February 12, 2014, the Securities Division made an Entry of Findings of Fact and Conclusions of Law and Final Order to Cease and Desist, Impose a Fine, and Charge Costs (“Final Order”), as to Respondents Lakemont Commercial Consulting, LLC; Larrick Holdings LLC; and Larry F. Allen. The Securities Division had previously entered a Statement of Charges and Notice of Intent to Enter an Order to Cease and Desist, Impose a Fine, and Charge Costs, on January 8, 2014. The Securities Division alleged that Respondents, doing business in Bellevue, Washington, had offered and sold more than $3 million worth of investments to at least eleven investors from 2008 through 2010. The Securities Division alleged that Respondents violated RCW 21.20.010, the anti-fraud section of the Securities Act of Washington, by misrepresenting or failing to disclose material information to investors. The Final Order orders Respondents to cease and desist from violating the Securities Act of Washington and orders Respondent Larry F. Allen to pay a fine of $10,000 and investigative costs of $5,000. Respondents each have a right to request judicial review of the Final Order.


Richard A. Ames - S-12-1042-14-FO01 -Final Order

On February 12, 2014, the Securities Division made an Entry of Findings of Fact and Conclusions of Law and Final Order to Cease and Desist, Impose a Fine, and Charge Costs (“Final Order”), as to Richard A. Ames (“Respondent”). The Securities Division had previously entered a Statement of Charges and Notice of Intent to Enter an Order to Cease and Desist, Impose a Fine, and Charge Costs, on January 8, 2014. The Securities Division alleged that Respondent, doing business in Bellevue, Washington, had offered and sold approximately $2.8 million worth of investments to at least nine investors from 2008 through 2010. The Securities Division alleged that Respondent violated RCW 21.20.010, the anti-fraud section of the Securities Act of Washington, by misrepresenting or failing to disclose material information to investors. The Final Order orders Respondent to cease and desist from violating the Securities Act of Washington and orders Respondent to pay a fine of $20,000 and investigative costs of $5,000. Respondent has a right to request judicial review of the Final Order.


Global Asset Research and Recovery; Petra Alluis - S-11-0692-14-FO01 - Final Order

On February 12, 2014, the Securities Division issued the Entry of Findings of Fact and Conclusions of Law and Final Order to Cease and Desist, To Impose a Fine, and To Charge Costs (“Final Order”) against Petra Alluis dba Global Asset Research and Recovery (“Respondent”). The Final Order orders Respondent to cease and desist from violating RCW 21.20.010 and RCW 21.20.140. The Final Order also orders Respondent to pay a fine of $10,000 and investigative costs of $1,000. Respondent has a right to request judicial review of the Final Order.


Fresh Healthy Vending, LLC - S-13-1304-14-SC01 - Statement of Charges

On February 11, 2014, the Securities Division entered a Statement of Charges and Notice of Intent to Enter an Order to Cease and Desist against Respondent Fresh Healthy Vending. The Statement of Charges alleges that the Respondent violated the Franchise Investment Protection Act by offering and selling vending machine franchises in Washington. The Respondent was not registered to sell franchises in Washington at the time, and the franchise was neither registered nor exempt from registration. The Statement of Charges further alleges that the Respondent failed to disclose material information in the franchise disclosure document that it provided to actual and potential Washington franchisees, and that the Respondent violated a past order issued by the Division. The Securities Division intends to order the Respondent to cease and desist from violating RCW 19.100.020 and RCW 19.100.170, the registration and anti-fraud provisions of the Franchise Investment Protection Act. The Respondent has an opportunity for hearing in this matter.


Joe Toner – S-11-0620-13-CO02 – Consent Order

On February 5, 2014, the Securities Division entered into a Consent Order with Joe Toner (“Respondent”). The Securities Division had previously entered a Statement of Charges (S-11-0620-13-SC02) against the Respondent on May 31, 2013. The Securities Division alleged that Respondent 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, Respondent agreed to cease and desist from violating the Washington Securities Act. Respondent agreed to pay a fine of $2,500 and investigative costs of $1,000. Respondent waived his right to a hearing and judicial review of this matter.


William Madison Swayne II - S-10-249-14-CO01 - Consent Order

On February 4, 2014, the Securities Division entered into a Consent Order with William Madison Swayne II (“Respondent”). The Securities Division alleged that Respondent made unsuitable sales of tenant-in-common (“TIC”) investments to at least two of his customers during 2006. The Securities Division alleged that when offering and selling the TIC investments, Respondent violated the suitability section of the Securities Act of Washington. Respondent neither admitted nor denied the allegations, but agreed to cease and desist from any violation of the Securities Act of Washington. Respondent agreed to pay investigative costs of $5,000. Respondent waived his right to a hearing and to judicial review of this matter.


Pacific West Securities, Inc. - S-09-048-13-CO02 & S-10-249-14-CO02 &#- Consent Order

On February 4, 2014, the Securities Division entered into a Consent Order with Pacific West Securities, Inc. (“Respondent”). The Securities Division alleged that Pacific West Securities, Inc. failed to establish, maintain, and enforce an adequate supervisory system for the sale of tenant-in-common (“TIC”) investments. As a result, when at least two registered representatives make unsuitable TIC sales to their customers between 2006 and 2008, the firm approved the transactions. The Securities Division further alleged that Pacific West Securities, Inc. violated the suitability section of the Securities Act of Washington. The Respondent neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act of Washington. The Respondent agreed to pay a fine of $15,000 and investigative costs of $10,000. The Respondent waived its right to a hearing and to judicial review of this matter.


EJZ Investments, LLC and Ernest John Zoller – S-07-532-14-FO01 – Final Order

On February 3, 2014, the Director of the State of Washington Department of Financial Institutions entered a Final Order as to EJZ Investments, LLC and Ernest John Zoller a/k/a Ernest J. or Ernie Zoller of Carson City, Nevada. The Final Order orders Respondents EJZ Investments, LLC and Ernest John Zoller to 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 EJZ Investments, LLC and Ernest John Zoller to each pay a fine of $5,000 and to each pay investigative costs of $1,500. Respondents each has the right to petition the superior court for judicial review of the order.


Robert L. Edwards d/b/a E-Z Unlimited – S-08-181-14-FO01 – Final Order

On February 3, 2014, the Director of the State of Washington Department of Financial Institutions entered a Final Order as to Robert Edwards d/b/a E-Z Unlimited and a/k/a Robert L. or Bob Edwards of Post Falls, Idaho. The Final Order orders Respondent Edwards to 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 Respondent Edwards to pay a fine of $5,000 and to pay investigative costs of $2,500. Respondent has the right to petition the superior court for judicial review of the order.


Stephen F. Darnell - S-13-1393-14-CO01 – Consent Order

On January 30, 2014, the Securities Division entered into a Consent Order with Mr. Stephen F. Darnell. Mr. Darnell had been providing investment advice for compensation. After receiving a letter from the Securities Division informing him of the investment adviser registration requirements, Mr. Darnell refunded all compensation he received for providing investment advice to his clients. Thereafter, the Securities Division entered into a Consent Order with Mr. Darnell. The Consent Order concluded that Mr. Darnell acted as an unregistered investment adviser. In the Consent Order, Mr. Darnell agreed to cease and desist from violating the Securities Act of Washington and to pay a fine of $1,500. Mr. Darnell waived his rights to a hearing and judicial review of the matter.


iCooper, Inc. – S-11-0593-14-FO01 – Final Order

On January 30, 2014, the Securities Division issued the Entry of Findings of Fact and Conclusions of Law and Final Order to Cease and Desist, To Impose a Fine, and To Charge Costs (“Final Order”) against iCooper, Inc. and Ken Hines. The Final Order orders iCooper, Inc. and Ken Hines to cease and desist from violating RCW 21.20.010, RCW 21.20.040, and RCW 21.20.140. The Final Order also orders Ken Hines to pay fine of $5,000 and investigative costs of $1,000. Respondents iCooper, Inc. and Ken Hines have the right to request judicial review of the Final Order.


Mr. Oil Saver, LLC; Mr. Fire Safety, LLC; and Chris Daskalakis – S-13-1280-13-CO01 – Consent Order

On January 30, 2014, the Securities Division entered into a Consent Order with Mr. Oil Saver, LLC; Mr. Fire Safety, LLC; and Chris Daskalakis. In the Consent Order, the Securities Division alleged that Mr. Oil Saver, LLC and Mr. Fire Safety, LLC violated the registration provision of the Washington State Franchise Protection Act (the Act). The Division further alleged that Mr. Oil Saver, LLC and Chris Daskalakis violated the disclosure document and anti-fraud provisions of the Act. Without admitting or denying the Securities Division’s allegations, Respondents each agreed to cease and desist from violating the Act. Respondents further agreed to reimburse the Securities Division $3,000 for its costs of investigation. Respondents each waived their right to a hearing and judicial review of the matter.


Robin Thomas Naylor - S-09-048-13-CO01 – Consent Order

On January 27, 2014, the Securities Division entered into a Consent Order with Robin Thomas Naylor (“Respondent”). The Securities Division alleged that Naylor, while employed as a securities salesperson and investment adviser representative with Pacific West Securities, made unsuitable tenant-in-common (“TIC”) sales to at least two of his customers between 2007 and 2008. The Securities Division alleged that in offering and selling the TIC investments, Naylor violated the suitability section of the Securities Act of Washington. The Respondent neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act of Washington. The Respondent agreed to pay investigative costs of $2,500. The Respondent waived his right to a hearing and to judicial review of this matter.


Northwest Growers Association - S-13-1291-13-SC01 - Statment of Charges

On January 21, 2014, 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 Charles Feick, William Moore, James Harrison, and Northwest Growers Association, Inc. (“Respondents”). The Statement of Charges alleges that Respondents violated RCW 21.20.140 by offering and selling over $46,000 of unregistered Northwest Growers Association, Inc. stock. The Statement of Charges further alleges that Charles Feick, William Moore, and James Harrison acted as unregistered securities salespersons or broker-dealers in violation of RCW 21.20.040. The Statement of Charges also alleges that Respondents violated anti-fraud provisions of RCW 21.20.010. 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 Charles Feick was entered on February 14, 2014.

A Consent Order as to William Moore was entered on February 26, 2014.

A Consent Order as to James Harrison was entered on March 03, 2014.


John Griffith – S-11-0620-13-FO02 – Final Order

On January 15, 2014, the Securities Division entered a Final Order against John Griffith. The Securities Division had previously entered a Statement of Charges against John Griffith on May 31, 2013, alleging violations of the Securities Act for his role in selling unregistered securities. The Final Order stated that John Griffith failed to attend a Prehearing Conference on December 2, 2013 and that on December 4, 2013, Administrative Law Judge Leslie Birnbaum entered an Order of Default that dismissed the Respondent’s appeal. The Final Order ordered John Griffith to cease and desist from any further violations of RCW 21.20.140, RCW 21.20.040, and RCW 21.20.010. The Final Order also ordered John Griffith to pay a fine of $10,000 and administrative costs of $5,000. John Griffith has the right to petition the superior court for judicial review of the Final Order.


Marty Edward Paul – S-13-1144-13-SC01 – Statement of Charges

On January 13, 2014, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, Revoke Registration, Deny Future Registration Applications, Impose a Fine, and Charge Costs (Statement of Charges) against Marty Edward Paul, aka Martin Paul (Paul). The Statement of Charges alleges that Paul borrowed $6.5 million from a client, provided false information to his firm about the loan, provided false information to his firm about his outside business activities, introduced clients to investments away from his firm, and provided false information to the firm about his outside investments. The Statement of Charges alleges that Paul was terminated by his firm for borrowing the money from his client, and that he was sanctioned by FINRA for borrowing the money from his client and providing inaccurate information to his firm about the loan and his outside business activities. Further, the Statement of Charges alleges that Paul misrepresented his termination and regulatory history to the Securities Division. The Securities Division intends to order Paul to cease and desist from violating the Securities Act of Washington, to revoke Paul’s investment adviser representative registration, to deny future securities registration applications, impose a fine, and charge costs. The respondent has the right to request a hearing on the Statement of Charges.


Mondays off Music, Inc.; City Stream, Inc.; Michael Raley; and Andrea Braeutigam – S-12-1037-13-SC01 – Statement of Charges

On January 2, 2014, 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 Mondays off Music, Inc.; City Stream, Inc.; Michael Raley; and Andrea Braeutigam (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. The Securities Division also alleges that Respondents violated RCW 21.20.010, the anti-fraud provision of the Securities Act of Washington. Further, the Securities Division alleges that City Stream, Inc. and Michael Raley violated RCW 21.20.350 by filing a false or misleading document with the Division. 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.


Lakemont Commercial Consulting, LLC; Larrick Holdings LLC; Richard A. (“Rick”) Ames; and Larry F. Allen - S-12-1042-13-SC01 - Statement of Charges

On January 8, 2014, the Securities Division entered a Statement of Charges against Respondents Lakemont Commercial Consulting, LLC; Larrick Holdings LLC; Richard A. Ames; and Larry F. Allen. The Securities Division alleged that Respondents, doing business in Bellevue, Washington, offered and sold more than $3 million worth of investments to at least eleven investors from 2008 through 2010. The Securities Division alleged that Respondents each violated RCW 21.20.010, the anti-fraud provision of the Securities Act of Washington, because in connection with the offer and sale of promissory note investments, Respondents each misrepresented or failed to disclose material information to investors. The Statement of Charges gives notice of the Securities Division’s intent to order Respondents to cease and desist from violating the Securities Act of Washington, to impose fines, and to charge costs. The Respondents each have the right to request a hearing on the Statement of Charges.

A Final Order as to Richard A. Ames was entered on February 12, 2014.

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


Frederick Allan Bieber – S-11-0596-13-SC01 – Statement of Charges

On January 7, 2013, the Securities Division entered a Statement of Charges and Notice of Intent to Issue an Order to Deny Future Registrations, Impose Fines, and Charge Costs against Frederick Allan Bieber (“Respondent”). The Respondent was formerly employed as a securities salesperson with KMS Financial Services, Inc. (“KMS”) and later Pacific West Securities, Inc. (“Pacific West”). The Securities Division alleges that while employed at KMS, the Respondent entered into a personal financial transaction with a customer and arranged loans for and between customers. When the Respondent was later employed with Pacific West, he did not provide prompt written notice to his firm when he received compensation from an outside business activity. The Respondent also made material misstatements to his firm on annual compliance questionnaires regarding the outside compensation he received. The Securities Division alleges that the Respondent engaged in dishonest and unethical practices in the securities business. The Securities Division gave notice of its intent to deny future securities registration applications of the Respondent. The Securities Division also gave notice of its intent to impose a fine and recover costs. The Respondent has a right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on March 10, 2014.


Vendco Bros, Inc. – S-13-1301-13-CO01 – Consent Order

On January 2, 2014, the Securities Division entered into a Consent Order with Vendco Bros, Inc. The Securities Division alleged that Vendco Bros, Inc. violated the registration and disclosure provisions of the Business Opportunity Fraud Act of Washington. Without admitting or denying the Securities Division’s allegations, Vendco Bros, Inc. agreed to cease and desist from violating the Business Opportunity Fraud Act of Washington. Vendco Bros, Inc. further agreed to pay investigative costs of $500. Vendco Bros, Inc. waived its right to a hearing and judicial review of the matter.


Retirement Protection Services Wealth Management LLC; Gregg Alan Henderson – S-13-1210-13-CO01 – Consent Order

On January 2, 2014, the Securities Division entered into a Consent Order with Retirement Protection Services Wealth Management LLC (“RPSWM”) and Gregg Alan Henderson (collectively, “the Respondents”). The Securities Division had previously issued a Statement of Charges, S-13-1210-13-SC01, against the Respondents. The Securities Division 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 Securities Division further alleged that this conduct violated the Securities Act of Washington. Without admitting or denying the allegations, the Respondents agreed to the revocation of RPSWM’s investment adviser registration, the revocation of Mr. Henderson’s investment adviser representative registration, and the future denial of any investment adviser registration, investment adviser representative registration, broker-dealer registration, or security salesperson registration that the Respondents may seek in the future. The Respondents each waived their right to a hearing and judicial review of the matter.

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