Washington State Department of Financial Institutions

2011 Administrative Orders

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Raymond Francis Purdon - S-09-154-11-FO01 - Final Order

On December 21, 2011, the Securities Division entered a Final Order against Raymond Francis Purdon. The Final Order stated that the Respondent had failed to appear for Status Conferences on September 20, 2011 and October 5, 2011. The Respondent was subject to an Order of Default that was entered on October 5, 2011 by Administrative Law Judge Thomas P. Rack. The Final Order ordered the Respondent to cease and desist from any further violations of RCW 21.20.010 and denies future securities registration applications of the Respondent. The Final Order also ordered the Respondent to pay a fine of $10,000, and investigative costs of $500. The Respondent has the right to petition the superior court for judicial review of the order.

A Statement of Charges was previously entered against Raymond Francis Purdon on March 1, 2011.


Market4Cast Hedge Fund, LP; Michael George Calhoun - S-09-200-11-FO01 - Final Order

On December 19, 2011, the Securities Division entered a Final Order to Cease and Desist, Impose Fines, and Recover Costs against Market4Cast Hedge Fund, LP and Michael George Calhoun (collectively "Respondents"). The Securities Division previously entered a Statement of Charges against the Respondents on February 28, 2011. The Statement of Charges alleges that Respondent Calhoun offered and sold limited partnership interests in the Market4Cast Hedge Fund, LP, which he operated from his residence on Bainbridge Island, Washington. It is believed that limited partnership interests were sold to at least 12 investors, including at least one Oregon resident. The Securities Division further alleges that by maintaining the hedge fund, Respondent Market4Cast Hedge Fund, LP acted as an investment adviser and Respondent Calhoun acted as an investment adviser representative. The Securities Division alleges that the Respondents offered unregistered securities, acted as unregistered broker-dealers, securities salespersons, investment advisers, and/or investment adviser representatives, and violated the anti-fraud provision of the Securities Act of Washington. The Securities Division orders the Respondents to cease and desist from violating the Securities Act, and orders the Respondents to each pay a fine of $10,000, and to jointly pay investigative costs of $1,000. The Respondents have the right to request judicial review of this matter.


American Supply, Howard Leventhal - S-11-0709-11-SC01 - Statement of Charges

On December 19, 2011, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist against Howard Leventhal and American Supply of Ash Fork, Arizona. The Securities Division alleges that Howard Leventhal and American Supply sold a textile distributorship to a Washington resident in violation of the Business Opportunity Fraud Act. The Statement of Charges alleges the Respondents violated the registration, disclosure document, contract content and anti-fraud provisions of the Act, and 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 February 13, 2012.


Gregory Pinneo; East Edgar Partners, LLC; Franklin Avenue Partners, LLC; Yale Avenue Partners, LLC; 2344-2345 Franklin Twins, LLC - S-10-047-10-SC01 - Statement of Charges

On December 15, 2011, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, Impose Fines, and Recover Costs ("Statement of Charges") against Respondents, Gregory Pinneo ("Pinneo"); East Edgar Partners, LLC ("East Edgar Partners"); Franklin Avenue Partners, LLC ("Franklin Avenue Partners"); Yale Avenue Partners, LLC ("Yale Avenue Partners"); and 2344-2345 Franklin Twins, LLC ("Franklin Twins") (collectively, "Respondents"). The Statement of Charges 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, Franklin Avenue Partners, Yale Avenue Partners, and Franklin Twins to approximately 76 investors, the majority of whom were Washington residents. The Statement of Charges further alleges that Respondents violated the securities registration and anti-fraud provisions of the Securities Act of Washington. 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 fines and recover costs. The Respondents have a right to request a hearing on the Statement of Charges.

A Consent Order as to Franklin Twins was entered on August 28, 2013.

A Consent Order as to Franklin Avenue Partners was entered on August 28, 2013.

A Consent Order as to Gregory Pinneo and Yale Avenue Partners, LLC, was entered on April 4, 2013.

On June 2, 2014, DFI’s Director entered a Final Decision and Order as to East Edgar Partners, LLC dismissing the charges as to that entity.


Suhrco Real Estate Advisors, Inc. - S-11-0724-11-FO01 - Final Order

On December 8, 2011, the Securities Division entered a Final Order against Suhrco Real Estate Advisors, Inc. ("Suhrco"). The Securities Division previously entered a Statement of Charges and Notice of Intent to Suspend and/or Revoke Investment Adviser Registration and Impose Fines against Suhrco on August 19, 2011. The Statement of Charges alleged that Suhrco violated the Securities Act of Washington by failing to file the required annual fiscal year end balance sheet with the Securities Division, failing to file the required annual amendments to its Form ADV Part 1 and Part 2 with the Investment Adviser Registration Depository (“IARD”), failing to file a Form U-5 for a former investment adviser representative with IARD, and employing an unregistered investment adviser representative. The Securities Division revokes Suhrco’s investment adviser registration and orders Suhrco to pay a fine of $1,000. Suhrco has a right to request judicial review of this Final Order.


ECO Motor Company, Inc; David Joner - S-09-361-11-FO01 - Final Order

On December 5, 2011, the Securities Division entered a Final Order against ECO Motor Company, Inc. ("ECO"), and its CEO David Joner ("Joner") (collectively, the "Respondents"). The Securities Division had entered a Statement of Charges against the Respondents on October 14, 2011 that alleged that ECO, through Joner, offered and sold at least $372,000 worth of its stock to at least six Washington residents to raise capital for the development, manufacture, and marketing of a three-wheeled automobile designed by Joner. The Statement of Charges further alleged that Respondents violated the securities registration and anti-fraud provisions of the Securities Act of Washington (the "Act") and that Joner also violated the securities salesperson and broker-dealer registration section of the Act. The Final Order orders the Respondents to cease and desist from violating the Act and orders the Respondents to pay a fine of $10,000 and to reimburse the Securities Division for its investigative costs. The Respondents have the right to request judicial review of the Final Order.


Lonepeak Capital, Inc.; Visions Investment Group, LLC; Eric Foster - S-10-442-11-FO01 - Final Order

On December 2, 2011, the Securities Division entered a Final Order against Lonepeak Capital, Inc., Visions Investment Group, LLC, and Eric Foster (collectively, “Respondents”). The Securities Division had previously entered a Statement of Charges against Respondents and others on May 27, 2011. The Statement of Charges alleged that Lonepeak Capital, Inc. offered and sold a promissory note to a Washington couple. The Statement of Charges further alleged that Respondents violated the registration of securities provision of the Washington Securities Act (the “Act”), that Visions Investment Group, LLC and Eric Foster, each violated the Act’s registration of securities broker-dealers and salespersons provision, and that Respondents violated the Act’s anti-fraud provision. The Final Order orders the Respondents to cease and desist from violations of the Securities Act of Washington and orders Respondents to pay a fine and to reimburse the Securities Division its investigative costs. The Respondents have a right to request judicial review of the Final Order.


T&H Northwest, LLC and Tyler Gonty - S-09-134-11-SC01 - Statement of Charges

On November 30, 2011, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist against Tyler Gonty and T&H Northwest, LLC. The Securities Division alleges that from 2006 to 2009 Gonty, through T&H Northwest, LLC, raised over $700,000 from at least 80 investors in violation of the Securities Act of Washington for the production and distribution of adult movies and websites. The Statement of Charges alleges the Respondents violated the registration and anti-fraud provisions of the Securities Act, and gives notice of the Securities Division’s intent to enter an Order to Cease and Desist, to impose fines, and recover costs. Respondents have a right to request a hearing on the Statement of Charges.

A Final Order was entered in this matter on January 6, 2012.


Visions Investment Group, LLC - S-11-0577-11-FO01 - Final Order

On November 29, 2011, the Securities Division entered a Final Order against Visions Investment Group, LLC ("Visions"). The Securities Division had previously issued a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist against Visions on May 27, 2011. The Statement of Charges alleged that Visions offered and sold a business opportunity consisting of training to enable the purchaser to begin a real estate investment business to at least one Washington resident while not registered to do so under the Business Opportunity Fraud Act of Washington. The Statement of Charges also alleged that Visions failed to provide material information and disclosure documents concerning the business opportunity. The Final Order orders Visions to cease and desist from violating the Business Opportunity Fraud Act of Washington. Visions has the right to request judicial review of the Final Order.


ATComm ATM, LLC; George Huntington - S-11-0772-11-CO01 - Consent Order

On November 28, 2011, the Securities Division entered into a Consent Order with George Huntington and ATComm ATM, LLC ("Respondents"). Respondents are in the business of selling automatic teller machines and services to find locations for automatic teller machines. In the Consent Order, the Division alleged that the Respondents sold unregistered business opportunities, failed to deliver a disclosure document to the purchasers, failed to provide contract provisions required by law and made material misrepresentations with regard to earnings claims in violation of the Business Opportunity Fraud Act. Without admitting or denying the Securities Division's allegations, Respondents agreed to cease and desist from violating the registration section, the disclosure document section, the contract section and the anti-fraud section of the Act. Respondents further agreed to reimburse the Securities Division $1,000 for its costs of investigation. Respondents waived their rights to a hearing and judicial review of the matter.


Raymond James & Associates, Inc. and Raymond James Financial Services, Inc. - S-11-0740-11-CO01 - Consent Order

On November 22, 2011, the Securities Division entered into a Consent Order with Raymond James & Associates, Inc. and Raymond James Financial Services, Inc. (collectively "Respondents"), in order to settle the allegations that the Respondents engaged in dishonest or unethical practices in the sale of auction rate securities ("ARS"), and failed to reasonably supervise its salespersons in the marketing and sale of ARS. The Respondents neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act of Washington. The Respondents agreed to offer to purchase at par ARS that since February 13, 2008 have not been auctioning from certain investors who purchased those ARS from the Respondents on or before February 13, 2008. The Respondents agreed to pay $8,363.42 as a civil monetary penalty. The Respondents waived their right to a hearing and to judicial review of this matter.


Patrick Leonard (aka Patrick Snetsinger) dba Snetsinger and Co., Snetsinger and Associates, The Children's Arbor, and Abacus - S-11-0663-11-FO01 - Final Order

On November 17, 2011, the Securities Division entered a Final Order against Patrick Leonard (also known as Patrick Snetsinger), doing business as Snetsinger and Co., Snetsinger and Associates, The Children's Arbor, and Abacus ("Respondent"). The Securities Division previously entered a Statement of Charges against Respondent on October 19, 2011. The Statement of Charges alleged that Respondent solicited at least 10 Washington residents to invest in a variety of investment opportunities and advisory services. The Statement of Charges alleged that Respondent had approximately $2,000,000 of investors' funds in his control. The Statement of Charges also alleged that Respondent spent over $380,000 of investors' funds on his personal expenses. The Statement of Charges further alleged that Respondent offered and/or sold unregistered securities, acted as an unregistered investment adviser, employed a scheme to defraud investors, and made misrepresentations and/or omissions to Washington residents regarding investment opportunities. The Securities Division orders Respondent to cease and desist from violating the Securities Act of Washington, to pay a fine of $50,000, and to pay investigative costs of $5,000. The Securities Division also bars Respondent from being licensed as a securities professional in the state of Washington. Respondent has a right to request judicial review of this Final Order.


Thomas Doncaster - S-06-137-11-CO01 - Consent Order

On November 10, 2011, the Securities Division entered into a Consent Order with Thomas Doncaster in connection with his alleged offer and sale of unsuitable variable annuities to customers, some of whom were elderly. 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, S-06-137-08-SC01, against Doncaster on January 26, 2010. The Statement of Charges alleged that Mr. Doncaster falsified account applications, provided clients with unauthorized financial projections, and engaged in other misleading conduct. Doncaster neither admitted nor denied the allegations, but agreed to cease and desist from any violation of RCW 21.20.010, the anti-fraud section of the Securities Act of Washington ("the Act"); RCW 21.110, the dishonest and unethical business practices section of the Act; RCW 21.20.702, the suitability of recommendations section of the Act; RCW 21.20.040, the registration section of the Act; and WAC 460-22B-090, the dishonest and unethical business practices section of the Washington Administrative Code. Doncaster agreed to pay investigative costs of $7,000. Doncaster waived his right to a hearing and to judicial review of the matter.


Wellspring Industry, Inc. d/b/a Tutti Frutti Frozen Yogurt - S-10-303-11-CO01 - Consent Order

On November 9, 2011, the Securities Division entered into a Consent Order with Wellspring Industry, Inc. d/b/a Tutti Frutti Frozen Yogurt ("Respondent"). 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 Respondent on May 3, 2011. Respondent is in the business of selling frozen yogurt products under the trademark Tutti Frutti Frozen Yogurt and is "a specialty frozen yogurt retailer with over 100 upcoming stores nation and world wide." The Statement of Charges alleged that Respondent offered and sold a franchise to at least two Washington residents while not registered under the Franchise Investment Protection Act, RCW 19.100. The Statement of Charges further alleged that Respondent failed to comply with the delivery of offering circular provision of the Franchise Investment Protection Act. 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 Franchise Investment Protection Act. Respondent further agreed to reimburse the Securities Division $1,200 for its costs of investigation. Respondent waived its right to a hearing and judicial review of the matter.


Willie Louis Jones, Eddie Baker - S-10-438-11-SC01 - Statement of Charges

On November 9, 2011, 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 Willie Louis Jones and Eddie Baker (collectively “Respondents”). The Statement of Charges alleges that Respondents solicited Washington residents in King and Pierce counties to invest in a variety of investment opportunities involving real estate ventures. The Statement of Charges also alleges that Respondent Jones procured over $500,000 of investors’ funds. The Statement of Charges further alleges that Respondents offered and/or sold unregistered securities, acted as unregistered securities salespersons, and made misrepresentations and/or omissions to Washington residents regarding investment opportunities. 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 collect fines and charge costs. Respondents have a right to request a hearing on the Statement of Charges.

A Consent Order as to Willie Louis Jones was entered on October 2, 2012.

A Final Order for Eddie Baker was entered on February 2, 2012.


Blair Smith - S-10-246-11-SC01 - Statement of Charges

On November 7, 2011, the Securities Division entered a Statement of Charges and Notice of Intent to Issue an Order to Cease and Desist, Impose Fines, and Charge Costs against the Respondent Blair Smith. The Statement of Charges alleges that for over eleven years the Respondent has transacted business as an investment adviser in Washington by providing investment advisory services from its principal place of business in Bellingham, Washington, without being properly registered. The Securities Division ordered the Respondent to cease and desist from violating the investment adviser registration provision of the Securities Act of Washington. The Securities Division gave notice of its intent to collect fines and charge costs. The Respondent has a right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on November 19, 2012.


BlueRay Technologies, LLC; BlueStar Technologies, Inc.; BlueStar Digital Technologies, Inc.; Erick Hansen; Matthew Richmond; Brandie Miller; Sean Michael - S-09-478-11-TO01 - Summary Order

On October 26, 2011, the Securities Division entered a Summary Order to Cease and Desist, and Notice of Intent to Impose Fines and Charge Costs ("Summary Order") against Respondents, BlueRay Technologies, LLC; BlueStar Technologies, Inc.; BlueStar Digital Technologies, Inc.; Erick Hansen; Matthew Richmond; Brandie Miller; and Sean Michael (collectively, "Respondents."). The Summary Order alleges that Hansen offered and sold investments in various companies he formed and controlled in an effort to raise funds to manufacture and produce Blu-ray discs, products, and hardware, and that the solicitation for investments and ongoing offers continued into 2011. The Summary Order alleges that BlueRay Technologies, LLC offered and sold approximately $4.7 million worth of LLC interests to approximately 107 investors, including about $399,700 to approximately 10 Washington residents, and also engaged in a second round offering of its Class B units in an attempt to raise additional capital. The Summary Order further alleges that Hansen offered and sold stock in BlueStar Technologies, Inc.; solicited capital for BlueStar Digital Technologies, Inc.; and offered investors the opportunity to exchange their BlueRay Technologies, LLC interests and BlueStar Technologies, Inc. stock for BlueStar Digital Technologies, Inc. stock. The Securities Division orders the Respondents to cease and desist from violating the securities registration, broker-dealer and/or securities salesperson registration, and anti-fraud provisions of the Securities Act of Washington. The Securities Division also gave notice of its intent to collect fines and charge costs. Respondents have the right to request a hearing on the Summary Order.

A Consent Order was entered regarding this matter on February 29, 2012.


Sansani Manphakdee - S-11-0655-11-SC01 - Statement of Charges

On October 19, 2011, the Securities Division entered a Statement of Charges and Notice of Intent to Enter an Order to Cease and Desist, Impose Fines, and Recover Costs against Sansani Manphakdee ("Manphakdee"), a/k/a Sansanee Manpakdee, who did busxiness as Global Pacific Traders Group. The Statement of Charges alleges that between approximately 2006 and 2008, Manphakdee raised over $500,000 by offering and selling investments in Global Pacific Traders Group, a purported international investment trading network. The Statement of Charges alleges that Manphakdee violated the registration and anti-fraud provisions of the Securities Act of Washington. The Securities Division intends to order Manphakdee to cease and desist from violating the Securities Act of Washington, and gives notice of its intent to impose a fine and recover costs. Manphakdee has a right to request a hearing on the Statement of Charges.


Patrick Leonard (also known as Patrick Snetsinger), dba Snetsinger and Co., Snetsinger and Associates, The Children’s Arbor, and Abacus - S-11-0663-11-SC01 - Statement of Charges

On October 19, 2011, 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 Recover Costs ("Statement of Charges") against Patrick Leonard (also known as Patrick Snetsinger), doing business as Snetsinger and Co., Snetsinger and Associates, The Children’s Arbor, and Abacus ("Respondent"). The Statement of Charges alleges that Respondent solicited at least 10 Washington residents to invest in a variety of investment opportunities and advisory services. The Statement of Charges alleges that Respondent had approximately $2,000,000 of investors’ funds in his control. The Statement of Charges also alleges that Respondent spent over $380,000 of investors’ funds on his personal expenses. The Statement of Charges further alleges that Respondent offered and/or sold unregistered securities, acted as an unregistered investment adviser, employed a scheme to defraud investors, and made misrepresentations and/or omissions to Washington residents regarding investment opportunities. The Securities Division intends to order Respondent to cease and desist from violating the Securities Act of Washington, and gave notice of its intent to deny future registrations, collect fines, and recover costs. Respondent has a right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on November 17, 2011.


ECO Motor Company, Inc.; David Joner - S-09-361-11-SC01 - Statement of Charges

On October 14, 2011, 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 (the "Statement of Charges") against ECO Motor Company, Inc. ("ECO"), and its CEO David Joner ("Joner") (collectively, the "Respondents"). The Statement of Charges alleges that ECO, through Joner, offered and sold at least $372,000 worth of its stock to at least six Washington residents to raise capital for the development, manufacture, and marketing of a three-wheeled automobile designed by Joner. The Statement of Charges further alleges that Respondents violated the securities registration and anti-fraud provisions of the Securities Act of Washington (the "Act") and that Joner also violated the securities salesperson and broker-dealer registration section of the Act. The Securities Division intends to order the Respondents to cease and desist from violating the Act and gives notice of its intent to impose fines and recover costs. The Respondents have the right to request a hearing on the Statement of Charges.

A Final Order regarding this matter was entered on December 5, 2011.


Irene Blomberg d/b/a Local Investments – S-11-0598-11-CO01 - Consent Order

On October 14, 2011, the Securities Division entered into a Consent Order with Irene Blomberg, doing business as Local Investments (“Respondent”). The Securities Division had previously entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, Impose Fines, and Recover Costs (“Statement of Charges”) against Respondent on July 26, 2011. The Statement of Charges alleged that Respondent helped raise $140,000 from three Washington residents by participating in unregistered securities transactions in Lopez Island, Washington. The Statement of Charges also alleged that Respondent solicited a total of nineteen potential Washington investors. The Statement of Charges further alleged that Respondent offered and/or sold unregistered securities, acted as an unregistered broker-dealer or securities salesperson, and made misrepresentations and/or omissions to Washington residents regarding investment opportunities. Respondent neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act. Respondent agreed to pay investigative costs of $750. Respondent waived her right to a hearing and to judicial review of this matter.


Xanadu, Inc. - S-11-0818-11-TO01 - Summary Order

On October 13, 2011, the Securities Division entered a Summary Order Denying Exemption and Statement of Charges and Notice of Intent to Enter an Order to Cease and Desist and to Revoke Exemptions against Xanadu, Inc. Xanadu, Inc. was formed to build a private vacation club and seeks 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 alleges that Xanadu, Inc. does not meet the requirements for the exemption claimed. The Order further alleges that the offering documents posted by Xanadu, Inc. on its website contain misstatements or omissions of material information. The Securities Division enters an Order denying the exemption for mutual or cooperative associations and gives notice of its intent to order Xanadu, Inc. to cease and desist from violating the Securities Act of Washington and to revoke 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 a hearing on the Order.

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


Patrick Reagan; John C. Shriner; The World Bikini Sports League, LLC (now known as The World Women's Sports Association) - S-09-464-10-CO01 - Consent Order

On October 13, 2011, the Securities Division entered into a Consent Order with Patrick Reagan ("Reagan"), John C. Shriner ("Shriner"), and The World Bikini Sports League, LLC ("TWBSL") (now known as The World Women's Sports Association) (collectively, "Respondents"). The Securities Division had previously entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, Impose Fines, and Recover Costs against Respondents on July 20, 2010. TWBSL was a football league featuring women playing football in bikinis. The Statement of Charges alleged that Respondents offered and sold investments, in the form of membership units in TWBSL, to approximately fifteen Washington investors, raising approximately $228,500. The Statement of Charges further 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. Respondents neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act. Respondents Reagan and Shriner agreed to pay a fine of $1,500 and investigative costs of $1,500. Respondents each waived their right to a hearing and to judicial review of this matter.


Financial Services International Corp.; Candace Jean Lee; David Waldemar Asplund, Jr.; and George “Tripp” Wallace Hook, III - S-09-343-10-SC01 - Statement of Charges

On October 6, 2011, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, Suspend Registrations, Impose Fines, and Recover Costs (“Statement of Charges”) against Financial Services International Corp. (“FSIC”); Candace Jean Lee (“Lee”); David Waldemar Asplund, Jr.(“Asplund”); and George “Tripp” Wallace Hook, III (“Hook”) (Collectively “Respondents”). The Statement of Charges alleges that Asplund and Hook made unsuitable recommendations of Class C shares of mutual funds (“C shares”), typically a short-term investment, to clients with long-term investment objectives. The Statement of Charges also alleges that by failing to enter into written advisory agreements, failing to provide disclosure documents, and failing to provide a complete description of the share class options and fees of mutual funds, FSIC and Lee engaged in a practice which would operate as a deceit. The Statement of Charges further alleges that FSIC and Lee failed to reasonably supervise FSIC representatives in the offer and sale of C shares. 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 suspend registrations, impose fines, and charge costs. Respondents have a right to request a hearing on the Statement of Charges.

A Consent Order as to FSIC and Candace Jean Lee was entered on August 1, 2012.

The matters alleged in S-09-343-10-SC01 as to George “Tripp” Wallace Hook, III were resolved on August 2, 2012 with the issuance of a Letter of Caution.


David Waldemar Asplund Jr - S-07-478-11-SC01 - Statement of Charges

On October 6, 2011, 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 Recover Costs against David Waldemar Asplund Jr. ("Respondent"). The Securities Division alleges that the Respondent, a former securities salesperson and investment adviser representative with FSIC, engaged in dishonest and unethical practices with respect to two of his Washington resident customers. The Respondent borrowed $40,000 from one customer, and accepted gifts, entered into a personal financial transaction, and acted as attorney-in-fact and co-trustee for another customer. The Securities Division alleges that the Respondent failed to have his securities salesperson application, Form U-4, updated within 30 days of being named as co-trustee. In addition, the Respondent caused to be filed two amendments to his Form U-4 which did not disclose his position as co-trustee, thus causing false or misleading filings to be made with the Securities Division. The Securities Division intends to order that the Respondent cease and desist from violating the Securities Act of Washington, and 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 as to David Waldemar Asplund, Jr., was entered on August 16, 2012.

A Final Order was entered regarding this matter on February 1, 2012.


Michael D. Sellers; Robert Keskemety; MovieBank, LLC; Vlad Investments, LLC - S-11-0578-11-FO01 - Final Order

On October 6, 2011, the Securities Division entered a Final Order against Michael D. Sellers, Robert Keskemety, MovieBank, LLC, and Vlad Investments, LLC. The Securities Division previously entered a Statement of Charges against Michael D. Sellers, Robert Keskemety, MovieBank, LLC, Vlad Investments, LLC, and alleged salespersons for the companies on August 29, 2011. The Statement of Charges alleged that Respondents raised at least $87,250 from Washington residents by offering and selling unregistered interests in film production and distribution companies. The Statement of Charges further alleged that Respondents Michael D. Sellers and Robert Keskemety, among other individuals, acted as unregistered broker-dealers and/or securities salespersons. The Statement of Charges also alleged that the offer and sale of securities by Respondents violated the anti-fraud provision of the Securities Act of Washington. The Securities Division orders Respondents Michael D. Sellers, Robert Keskemety, MovieBank, LLC, and Vlad Investments, LLC to cease and desist from violating the Securities Act of Washington and to pay investigative costs of $6,350. The Securities Division also orders Respondent Michael D. Sellers to pay a fine of $20,000. Respondents Michael D. Sellers, Robert Keskemety, MovieBank, LLC, and Vlad Investments, LLC have a right to request judicial review of this Final Order.


Renue Systems Development Corp. Inc., formerly known as National Appeal Development Corp. Inc. - S-11-0789-11-CO01 - Consent Order

On September 30, 2011, the Securities Division entered into a Consent Order with Renue Systems Development Corp., Inc., formerly known as National Appeal Development Corp., Inc., of Addison, Illinois, in which the Division alleged that the company offered and sold unregistered carpet and upholstery cleaning, restoration and maintenance franchises and failed to provide a disclosure document to an offeree in violation of the state Franchise Act. Without admitting or denying the Securities Division’s allegations, Renue Systems Development Corp., Inc. agreed to cease and desist from violating the registration and disclosure document provisions of the state Franchise Act. Renue Systems Development Corp., Inc. further agreed to reimburse the Securities Division $1,200 for its costs of investigation. Renue Systems Development Corp., Inc. waived its right to a hearing and judicial review of the matter.


Commercial Property Consultants, LLC - S-10-242-11-FO01 - Final Order

On September 19, 2011, the Securities Division entered a Final Order against Commercial Property Consultants, LLC (“Respondent”). The Securities Division had previously entered a Statement of Charges against Respondent on June 2, 2011. Respondent was in the business of selling franchises that involved providing engineered cost segregation services to owners of commercial property. The Statement of Charges alleged that Respondent offered and sold franchises to three Washington residents while not registered under the Franchise Investment Protection Act, RCW 19.100. The Statement of Charges further alleged that Respondent violated the anti-fraud and disclosure document provisions of the Franchise Investment Protection Act in connection with the offer of the franchises. The Securities Division orders Respondent to cease and desist from violating the registration, anti-fraud and disclosure document provisions of the Franchise Investment Protection Act. Respondent has a right to request judicial review of the Final Order.


Michael D. Sellers, John Hart, Marshall Chilton, Paul J Campbell, Robert Keskemety, MovieBank, LLC, Vlad Investments, LLC - S-11-0578-11-SC01 - Statement of Charges

On  August 29, 2011, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, Impose Fines, and Charge Costs against Michael D. Sellers, John Hart, Marshall Chilton, Paul J. Campbell, Robert Keskemety, MovieBank, LLC, and Vlad Investments, LLC (collectively “Respondents”).  The Statement of Charges alleges that Respondents raised at least $87,250 from Washington residents by offering and selling unregistered interests in film production and distribution companies.  The Statement of Charges further alleges that Respondents Michael D. Sellers, John Hart, Marshall Chilton, Paul J. Campbell, and Robert Keskemety acted as unregistered broker-dealers and/or securities salespersons.  The Statement of Charges also alleges that the offer and sale of securities by Respondents violated the anti-fraud provision of the Securities Act of Washington.  The Securities Division ordered Respondents to cease and desist from violating the securities registration, broker-dealer and/or securities salesperson registration and anti-fraud provisions of the Securities Act of Washington.  The Securities 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 Final Order was entered regarding this matter on October 06, 2011.


Columbia City Cinema, Inc.; Paul Doyle - S-10-424-11-FO01 - Final Order

On August 22, 2011, the Securities Division entered a Final Order against Columbia City Cinema, Inc. (“CCC, Inc.”) and Paul Doyle (“Doyle”) (collectively, “Respondents”). The Securities Division had previously entered a Stop Order Denying Effectiveness of Application for Registration and Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, Impose Fines, and Charge Costs (“Stop Order”) against Respondents on December 2, 2010. CCC, Inc. was in the business of operating a “3-screen neighborhood cinema showing first run movies” in Seattle. The Stop Order alleged that the registration statement filed on behalf of CCC, Inc. was incomplete in a material respect or contained statements which are false or misleading. Among other things, CCC, Inc. failed to adequately describe the risks involved in investing in CCC, Inc. and did not address the promissory notes issued by its predecessor company, Columbia City Cinema, LLC. The Stop Order further alleged that Respondents offered CCC, Inc. stock through its website and a news story on King 5 News. The Stop Order alleged that Respondents offered unregistered securities and violated the anti-fraud provisions of the Securities Act of Washington. The Stop Order also alleged that Doyle acted as an unregistered securities salesperson or broker-dealer. The Securities Division orders Respondents to cease and desist from violating the Securities Act of Washington and to pay investigative costs of $1,000. Respondents have the right to request judicial review of this Final Order.


Charles W. Williams; Real Investor Mortgage, Inc.; Starlie, LLC - S-07-294-11-CO02 - Consent Order

On August 22, 2011, the Securities Division entered into a Consent Order, S-07-294-11-CO02, with Charles W. Williams; Real Investor Mortgage, Inc. (“RIM”); and Starlie, LLC. 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-07-294-10-SC01, against National Strategic Investment Corporation (“NSIC”); RIM; Starlie, LLC; Charles W. Williams and Steven M. Hettema (collectively “Respondents”) on December 17, 2010. NSIC was a Washington corporation that hosted educational courses regarding investment alternatives, with a focus on real estate investing. NSIC also managed an investor club with several locations in Washington and neighboring states. The Division alleged that Respondents raised a total of $876,834 by selling investments to members of the investor club located in Port Orchard. The Division alleged that Respondents sold investments in the purchase and remodel of a commercial building, and also investments in the form of promissory notes and promissory notes convertible to stock, the proceeds which were to be used to expand the NSIC and RIM businesses. 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. Charles W. Williams; RIM; and Starlie, LLC neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act, and to pay investigative costs of $1,800. Charles W. Williams; RIM; and Starlie, LLC each waived their right to a hearing and to judicial review of this matter.


Peters & Company, INC, P.S. - S-11-0722-11-SC01 - Statement of Charges

On August 19, 2011, the Securities Division entered a Statement of Charges and Notice of Intent to Suspend and/or Revoke Investment Adviser Registration and Impose Fines against Peters & Company, INC, P.S. (“Peters”). The Statement of Charges alleges that Peters violated the Securities Act of Washington by failing to file the required annual fiscal year end balance sheet with the Securities Division and failing to file the required annual amendments to its Form ADV Part 1 and Part 2 with the Investment Adviser Registration Depository. The Statement of Charges gives notice that the Securities Division intends to enter an order to suspend and/or revoke Peters' investment adviser registration and impose fines. Peters has the right to request a hearing on the Statement of Charges.


Suhrco Real Estate Advisors, Inc. - S-11-0724-11-SC01 - Statement of Charges

On August 19, 2011, the Securities Division entered a Statement of Charges and Notice of Intent to Suspend and/or Revoke Investment Adviser Registration and Impose Fines against Suhrco Real Estate Advisors, Inc. ("Suhrco"). The Statement of Charges alleges that Suhrco violated the Securities Act of Washington by failing to file the required annual fiscal year end balance sheet with the Securities Division, failing to file the required annual amendments to its Form ADV Part 1 and Part 2 with the Investment Adviser Registration Depository (“IARD”), failing to file a Form U-5 for a former investment adviser representative with IARD, and employing an unregistered investment adviser representative. The Statement of Charges gives notice that the Securities Division intends to enter an order to suspend and/or revoke Suhrco's investment adviser registration and impose fines. Suhrco has the right to request a hearing on the Statement of Charges.

A Final Order regarding this matter was entered on December 8, 2011.


Progolf International, Inc.; Ron Davies - S-09-419-11-CO01 - Consent Order

On August 17, 2011, the Securities Division entered into a Consent Order, S-09-419-11-CO01, with Progolf International, Inc. and Ron Davies (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 Charge Costs, S-09-419-09-SC01, against the Respondents on February 2, 2010. The Statement of Charges alleged that Respondents offered and sold investments, in the form of promissory notes, to two investors located in Washington. Respondents raised $250,000, which was used as working capital by Respondent Progolf International, Inc., a California corporation, to manufacture the “icady” product. The Statement of Charges alleged that Respondents offered unregistered securities, acted as unregistered broker-dealers or securities salespersons, and violated the anti-fraud provision of the Securities Act of Washington. Respondents neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act. Respondents agreed to pay investigative costs of $1,000. Respondents each waived their right to a hearing and to judicial review of this matter.


Timothy Charles Cross - S-10-170-11-CO01 - Consent Order

On August 15, 2011, the Securities Division entered into a Consent Order with Timothy Charles Cross (“Cross”). The Securities Division had previously entered a Statement of Charges and Notice of Intent to Enter Order to Suspend Registrations, Impose a Fine, and Recover Costs, S-10-170-11-SC01, against Cross. Cross was the designated supervisor for Rhonda Lee Breard (“Breard”), a former securities salesperson and investment adviser representative who, while subject to Cross’s supervision, engaged in a scheme to defraud many of her brokerage customers. From at least July 2003 to February 2010, Breard converted at least $12 million dollars from 42 of her customers for her personal use. The Securities Division alleged that Cross failed to reasonably supervise Breard by failing to adequately review her business checking account records. The Securities Division further alleged that as a result of Cross’s failure to reasonably question Breard’s bank account activity, she was able to continue to convert funds from her customers for an extended period of time. Cross neither admitted nor denied the allegations, but agreed to pay a fine of $10,000 and investigative costs of $5,000. Cross waived his right to a hearing and to judicial review of this matter.


Texas State Energy Corporation - S-11-0584-11-FO01 - Final Order

On July 28, 2011, the Securities Division entered a Final Order against Texas State Energy Corp.  The Securities Division previously entered a Statement of Charges against Texas State Energy Corp. (“TSEC”) and an alleged salesperson for the company on May 27, 2011.  The Statement of Charges alleged that TSEC raised $20,000 from an eighty-six-year-old Washington resident by offering and selling unregistered interests in an oil well project.  The Statement of Charges also alleged that the offer and sale of securities by TSEC violated the anti-fraud provision of the Securities Act of Washington.  The Securities Division orders Respondent Texas State Energy Corp. to cease and desist from violating the Securities Act of Washington, to pay a fine of $10,000, and to pay investigative costs of $5,000.  Respondent Texas State Energy Corp. has a right to request judicial review of this Final Order.


Mitchell A. Steitz - S-10-451-11-SC01 - Statement of Charges

On July 26, 2011 the Securities Division entered a Statement of Charges and Notice of Intent to Enter an Order to Cease and Desist, Deny Future Registrations, Impose Fines and Recover Costs (“Statement of Charges”) against Mitchell A. Steitz (“Respondent”). The Statement of Charges alleges that Respondent engaged in dishonest and unethical practices while working as a securities salesperson, and that these practices are grounds for denial of his future securities registration applications. The Statement of Charges alleges that Respondent solicited a customer to invest a total of $12,500 in an investment which Respondent claimed was only available to employees of the broker-dealer which he represented. The Statement of Charges also alleges that Respondent later indicated that he used the customer’s funds for “personal reasons” and did not invest it. The Securities Division further alleges that in offering and selling the investment, Respondent 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 he represented. The Securities Division intends to order that Respondent cease and desist from violating the Securities Act of Washington, and gave notice of its intent to deny future securities registration applications of Respondent. The Securities Division also gave notice of its intent to impose fines and recover costs. Respondent has a right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on May 9, 2012.


BFK Franchise Company, LLC d/b/a Bricks 4 Kidz - S-11-0617-11-CO01 - Consent Order

On July 26, 2011, the Securities Division entered into a Consent Order with BFK Franchise Company, LLC d/b/a Bricks4Kidz, of St. Augustine, Florida, in which the Division alleged that the company offered and sold unregistered franchises and failed to provide a disclosure document to offerees in violation of the state Franchise Act. Without admitting or denying the Securities Division’s allegations, BFK Franchise Company, LLC agreed to cease and desist from violating the registration and disclosure document provisions of the state Franchise Act. BFK Franchise Company, LLC further agreed to reimburse the Securities Division $1,500 for its costs of investigation. BFK Franchise Company, LLC waived its right to a hearing and judicial review of the matter.


Irene Blomberg d/b/a Local Investments - S-11-0598-11-SC01 - Statement of Charges

On July 26, 2011 the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, Impose Fines, and Recover Costs ("Statement of Charges") against Irene Blomberg, doing business as Local Investments ("Respondent"). The Statement of Charges alleges that Respondent helped raise $140,000 from three Washington residents by participating in unregistered securities transactions in Lopez Island, Washington. The Statement of Charges further alleges that Respondent solicited a total of nineteen potential Washington investors. The Statement of Charges alleges that Respondent offered and/or sold unregistered securities, acted as an unregistered broker-dealer or securities salesperson, and made misrepresentations and/or omissions to Washington residents regarding investment opportunities. The Securities Division intends to order Respondent to cease and desist from violating the Securities Act of Washington, and gave notice of its intent to collect fines and recover costs. Respondent has a right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on October 14, 2011.


Vend Natural, Inc. - S-10-435-11-CO01 - Consent Order

On July 26, 2011, the Securities Division entered into a Consent Order with Vend Natural, Inc. of Ventura, California, in which the Division alleged that the company offered and sold an unregistered vending machine business opportunity and failed to provide a disclosure document to the purchaser in violation of the state Business Opportunity Act. Without admitting or denying the Securities Division’s allegations, Vend Natural, Inc. agreed to cease and desist from violating the registration and disclosure document provisions of the state Business Opportunity Act. Vend Natural, Inc. further agreed to reimburse the Securities Division $800 for its costs of investigation. Vend Natural, Inc. waived its right to a hearing and judicial review of the matter.


Financial Solutions II, LLC; Neal T. Ische; and Theodore C. Dutcher - S-10-261-11-FO01 - Final Order

On July 11, 2011, the Securities Division entered a Final Order to Cease and Desist, to Impose a Fine, and to Charge Costs ("Final Order"), as to Respondent, Neal T. Ische ("Ische"). The Securities Division previously entered a Statement of Charges against Ische on May 20, 2011. The Securities Division found that Ische had failed to make a timely hearing request on the Statement of Charges. The Securities Division found that from at least 2004 through 2006, Ische participated in offering and selling more than $950,000 worth of investments to at least twelve investors or prospective investors in natural gas well production. The Securities Division found that Ische had violated the registration and the anti-fraud provisions of the Securities Act of Washington and ordered Ische to cease and desist from any further violations and ordered Ische to pay a fine and costs. Ische has the right to request judicial review of the Final Order.


Eddyline Kayaks, LLC; Thomas V. Derrer; and Elisabeth C. Derrer - S-11-0575-11-CO01 - Consent Order

On June 30, 2011, the Securities Division entered into a Consent Order with Respondents, Eddyline Kayaks, LLC; Thomas V. Derrer; and Elisabeth C. Derrer.  Respondents neither admit nor deny the Findings of Fact and Conclusions of Law set forth in the Consent Order.  Eddyline Kayaks, LLC (“Eddyline”) manufactures and sells sea kayaks and has its principal place of business in Burlington, Washington.  The Derrers are the managing members of Eddyline.  The Securities Division alleged that from 2004 through 2011, Respondents offered and sold two types of investments totaling more than $680,000 to more than sixty investors.  The Securities Division alleged that the investments had terms ranging from eight months to five years with annual interest rates ranging from 7% to 10%.  The Securities Division alleged that when offering and selling the investments, Respondents each violated the registration and anti-fraud provisions of the Securities Act of Washington (“Securities Act”).  As a condition for entering into the Consent Order, Respondents each filed an affidavit listing all of the outstanding investments and the amounts owed to each investor.  Prior to the entry of the Consent Order, Respondents, through their attorney, repaid all of the principal and accrued interest that was owed to all of the investors.  It was agreed and ordered that Respondents would each cease and desist from any further violations of the Securities Act.  Respondents each waived their rights to a hearing and to judicial review of the matter.


David R. Huetten d/b/a DRH Funding, d/b/a DRH Investment Corp., d/b/a DRH One, Inc. - S-07-069-11-FO01 - Final Order

On June 28, 2011, the Securities Division entered a Final Order against David R. Huetten (“Huetten”) d/b/a DRH Funding, d/b/a DRH Investment Corp., d/b/a D R H One, Inc.  The Securities Division previously entered a Statement of Charges against Huetten on April 11, 2011.  The Statement of Charges alleged that between approximately 2004 and 2006, Huetten raised at least $3 million by offering and selling securities in the form of interests in limited liability companies that were formed as part of various real estate investment programs.  The Statement of Charges alleged that Huetten violated the registration and anti-fraud provisions of the Securities Act of Washington.  The Securities Division orders Huetten to cease and desist from violating the Securities Act of Washington, and orders Huetten to pay a fine and costs.  Huetten has a right to request a review of the Final Order.


Westgate Advisors, Inc.; Thomas Signorelli - S-10-333-11-CO01 - Consent Order

On June 9, 2011, the Securities Division entered into a Consent Order with Westgate Business Finance, Inc. and its President, Thomas Signorelli (collectively, “Respondents”) in settlement of a prior Statement of Charges. The Statement of Charges alleged that Respondents offered and sold an unregistered business opportunity, failed to provide a disclosure document to the purchaser, and made misstatements of material facts or omitted to state material facts in violation of the Business Opportunity Fraud Act of Washington. Without admitting or denying the Securities Division’s allegations, Respondents agreed to cease and desist from violating the Business Opportunity Fraud Act. Respondents waived their rights to a hearing and judicial review of the matter.


Centurion Financial Group, LLC; Thomas R. Hazelrigg III; and Scott G. Switzer - S-09-003-11-CO02  - Consent Order

On June 9, 2011, the Securities Division entered into a Consent Order with Respondents, Centurion Financial Group, LLC; Thomas R. Hazelrigg III; and Scott G. Switzer.  Respondents neither admitted nor denied the Findings of Fact and Conclusions of Law set forth in the Consent Order.  The Securities Division alleged that Respondents, doing business in Bellevue, Washington, were in the business of originating high-interest loans that were to be secured by real estate.  The Securities Division alleged that Respondents offered and sold promissory notes totaling more than $3,500,000.  The Securities Division alleged that Respondents each offered and sold unregistered securities and each violated the anti-fraud provision of the Securities Act of Washington when offering and selling promissory note investments.  The Securities Division imposed a fine of $10,000 jointly and severally against Respondents and charged investigative costs of $2,500 against Hazelrigg and Switzer.  However, the payment of fines and costs was suspended based upon future compliance with the Consent Order and based upon the Respondents’ inability to pay.  Respondents each waived their right to a hearing and to judicial review of the matter.


Commercial Property Consultants, LLC - S-10-242-11-SC01 - Statement of Charges

On June 2, 2011, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist (“Statement of Charges”) against Commercial Property Consultants, LLC (“Respondent”). Respondent was in the business of selling franchises that involved providing engineered cost segregation services to owners of commercial property. The Statement of Charges alleges that Respondent offered and sold franchises to three Washington residents while not registered under the Franchise Investment Protection Act, RCW 19.100. The Statement of Charges further alleges that Respondent violated the anti-fraud and disclosure document provisions of the Franchise Investment Protection Act in connection with the offer of the franchises. The Securities Division intends to order Respondent to cease and desist from violating the registration, anti-fraud and disclosure document provisions of the Franchise Investment Protection Act. Respondent has a right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on September 19, 2011.


Lonepeak Capital, Inc; Visions Investment Group, LLC; Eric Foster; Jonathan Lowry; Bryon Workman - S-10-442-11-SC01 - Statement of Charges

On May 27, 2011, 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 Lonepeak Capital, Inc., Visions Investment Group, LLC, Eric Foster, Jonathan Lowry, and Byron Workman (collectively, “Respondents”). The Statement of Charges alleges that Lonepeak Capital, Inc. offered and sold a promissory note to a Washington couple. The Statement of Charges further alleges that Lonepeak Capital, Inc. violated the registration of securities provision of the Washington Securities Act (the “Act”), that Visions Investment Group, LLC, Eric Foster, Jonathan Lowry, and Byron Workman each violated the Act’s registration of securities broker-dealers and salespersons provision, and that all Respondents violated the Act’s anti-fraud provision. The Securities Division intends to order the Respondents to cease and desist from violations of the Securities Act of Washington and gives notice of its intent to impose fines and 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 December 2, 2011.

A Final Order as to Jonathan Lowry was issued on November 19, 2012

A Final Order was to Byron Workman was entered on March 11, 2013.


Visions Investment Group, LLC - S-11-0577-11-SC01 - Statement of Charges

On May 27, 2011, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist against Visions Investment Group, LLC (“Visions”). The Statement of Charges alleges that Visions offered and sold a business opportunity consisting of training to enable the purchaser to begin a real estate investment business to at least one Washington resident while not registered to do so under the Business Opportunity Fraud Act of Washington (the “Act”). The Statement of Charges also alleges that Visions failed to provide material information and disclosure documents concerning the business opportunity. The Statement of Charges further alleges that Visions violated the Act’s anti-fraud provision. Visions has a right to request a hearing on the Statement of Charges.

A Final Order was entered in this matter on November 29, 2011.


Texas State Energy Corp; Thomas D Woodcock, Jr. - S-11-0584-11-SC01 - Statement of Charges

On May 27, 2011, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, Impose Fines, and Charge Costs against Texas State Energy Corp. and Thomas D. Woodcock, Jr. (collectively “Respondents”).  Respondents represented that they engage in oil and gas exploration.  The Statement of Charges alleges that Respondents raised $20,000 from an eighty-six-year-old Washington resident by offering and selling unregistered interests in an oil well project located in Montgomery County, Kansas.  The Statement of Charges further alleges that Respondent Woodcock acted as unregistered broker-dealer and/or securities salesperson.  The Statement of Charges also alleges that the offer and sale of securities by Respondents violated the anti-fraud provision of the Securities Act of Washington.  The Securities Division ordered Respondents to cease and desist from violating the securities registration, broker-dealer and/or securities salesperson registration and anti-fraud provisions of the Securities Act of Washington.  The Securities 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 Final Order as to Texas State Energy Corporation was entered on July 28, 2011. 


Timothy Charles Cross - S-10-170-11-SC01 - Statement of Charges

On May 27, 2011, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Suspend Registrations, Impose a Fine, and Recover Costs (“Statement of Charges”) against Timothy Charles Cross (“Cross”). Cross was the designated supervisor for Rhonda Lee Breard (“Breard”), a former securities salesperson and investment adviser representative who, while subject to Cross’s supervision, engaged in a scheme to defraud many of her brokerage customers. From at least July 2003 to February 2010, Breard converted at least $12 million from 42 of her customers for her personal use. The Statement of Charges alleges that Cross failed to reasonably supervise Breard by failing to adequately review her business checking account records. The Securities Division further alleges that as a result of Cross’s failure to reasonably question Breard’s bank account activity, she was able to continue to convert funds from her customers for an extended period of time. The Securities Division gave notice of its intent to suspend registrations, impose a fine, and recover costs. The Respondent has a right to request a hearing on the Statement of Charges.

A Consent Order regarding this matter was entered on August 15, 2011.


Corey V. Darling; Wealth Investment Group, LLC - S-10-008-11-CO01 - Consent Order

On May 27, 2011, the Securities Division entered into a Consent Order, S-10-008-11-CO01, with Corey V. Darling (“Darling”) and Wealth Investment Group, LLC (“Wealth Investment Group”) (collectively, “Respondents”). The Securities Division had previously entered a Statement of Charges and Notice of Intent to Enter an Order to Cease and Desist, Deny Future Registrations, Impose Fines and Recover Costs against Respondents on April 11, 2011. The Securities Division alleged that Darling engaged in dishonest and unethical practices while working as a securities salesperson and investment adviser representative. The Securities Division alleged that Darling offered and sold investments in the form of limited liability company membership interests in Wealth Investment Group to four Washington residents, three of whom were securities brokerage customers, and that he offered and sold a promissory note in the amount of $100,000 to another securities brokerage customer. The Securities Division further alleged that these securities transactions were not recorded on the books and records of the broker-dealer which Darling represented, as required by NASD Conduct Rule 3040. The Securities Division also alleged that Darling borrowed money from at least two securities brokerage customers, and by doing so, he failed to comply with FINRA Rule 3240 and engaged in dishonest or unethical practices as defined by WAC 460-22B-090(1). In settling the matter, Respondents neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act of Washington. Respondent Darling agreed that he will not apply for nor be granted a license as a broker-dealer, securities salesperson, investment adviser, or investment adviser representative in the State of Washington for a period of six (6) years from the date of entry of the Consent Order. Respondents each waived their right to a hearing and judicial review of the matter.


Financial Solutions II, LLC; Neal T. Ische; and Theodore C. Dutcher - S-10-261-11-SC01 - Statement of Charges

On May 20, 2011, the Washington 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, Financial Solutions II, LLC; Neal T. Ische; and Theodore C. Dutcher.  The Securities Division alleges that from at least 2004 through 2006, Respondents offered and sold more than $950,000 worth of investments to at least twelve investors or prospective investors in natural gas well production.  The Securities Division alleges that Respondents each violated the registration provisions and the anti-fraud provision of the Securities Act of Washington.  The Statement of Charges gave notice of the Securities Division’s intent to seek fines and costs against the Respondents.  Respondents each have the right to request a hearing on the Statement of Charges.

A Final Order as to Financial Solutions II, LLC and Theodore C Dutcher was entered on May 21, 2012.

A Final Order as to Neal Ische was entered on July 11, 2011.


Fairfield Energy Inc. TM4500 Rig Acquisition Joint Venture, LLC; Fairfield Energy Inc.; Brian Sullivan - S-07-351-11-FO01 - Final Order

On May 11, 2011, the Securities Division entered a Final Order against Fairfield Energy Inc. TM4500 Rig Acquisition Joint Venture, LLC; Fairfield Energy Inc.; and Brian Sullivan (collectively “Respondents”). The Final Order stated that Respondents had each failed to appear for a Prehearing Conference on December 16, 2010. Respondents were each subject to an Initial Order of Default that was entered on January 20, 2011 by Administrative Law Judge Steven C. Smith. The Final Order ordered Respondents 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 each Respondent to pay a fine of $5,000, and for the Respondents to pay investigative costs of $1,500. Respondents each have the right to petition the superior court for judicial review of the order.

The Securities Division had previously entered a Statement of Charges in this matter on March 30, 2009.


Vannox Diversified Entertainment, Inc. d/b/a Astro Jump and Astro Events - S-09-374-11-CO01 - Consent Order

On May 4, 2011, the Securities Division entered into a Consent Order with Vannox Diversified Entertainment, Inc. d/b/a Astro Jump and Astro Events (“Astro Jump”), in settlement of a prior Statement of Charges. The Statement of Charges alleged that Astro Jump offered and sold an unregistered franchise and failed to provide a disclosure document or offering circular to the purchaser in violation of the Franchise Investment Protection Act of Washington. Without admitting or denying the Securities Division’s allegations, Astro Jump agreed to cease and desist from violating the franchise registration and offering circular provisions of the Franchise Investment Protection Act of Washington. Astro Jump further agreed to reimburse the Securities Division $1,250 for its costs of investigation. Astro Jump waived its right to a hearing and judicial review of the matter.


Wellspring Industry, Inc. d/b/a Tutti Frutti Frozen Yogurt - S-10-303-11-SC01 - Statement of Charges

On May 3, 2011, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist (“Statement of Charges”) against Wellspring Industry, Inc. d/b/a Tutti Frutti Frozen Yogurt (“Respondent”). Respondent is in the business of selling frozen yogurt products under the trademark Tutti Frutti Frozen Yogurt and is “a specialty frozen yogurt retailer with over 100 upcoming stores nation and world wide.” The Statement of Charges alleges that Respondent offered and sold a franchise to at least two Washington residents while not registered under the Franchise Investment Protection Act, RCW 19.100. The Statement of Charges further alleges that Respondent failed to comply with the registration and delivery of offering circular provisions of the Franchise Investment Protection Act. The Securities Division intends to order Respondent to cease and desist from violating the Franchise Investment Protection Act. Respondent has a right to request a hearing on the Statement of Charges.

A Consent Order regarding this matter was entered on November 09, 2011.


Glenn Fulton - S-09-163-10-CO04 - Consent Order

On April 29, 2011, the Securities Division entered into a Consent Order, S-09-163-10-CO04, with Glenn Fulton. Previously, on May 21, 2010, the Securities Division entered a Statement of Charges, S-09-163-10-SC01, against NDG Investment Group, LLC (NDG), Mr. Fulton 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. Fulton, a former NDG employee, agreed, without admitting or denying the findings of fact, to cease and desist from violating the Securities Act of Washington. Mr. Fulton waived his rights to a hearing or other further proceedings in the matter.


New Earth Renewable Energy Inc. and Ahava Amen - S-10-289-11-SC01 - Statement of Charges

On April 12, 2011, 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 against Respondents, New Earth Renewable Energy Inc. (“New Earth”) and Ahava Amen.  The Securities Division alleged that the Respondents had claimed that New Earth was producing “E-Coal” and “E-Oil,” which were renewable sources of energy.  The Securities Division alleged that Respondents offered and sold more than $475,000 worth of New Earth convertible promissory notes to investors.  The Securities Division alleged that Respondents each violated the registration provision and the anti-fraud provision of the Securities Act of Washington.  The Statement of Charges gave notice of the Securities Division’s intent to seek fines and costs against the Respondents.  The Respondents each have the right to request a hearing on the Statement of Charges.


David R. Huetten d/b/a DRH Funding, d/b/a DRH Investment Corp., d/b/a DRH One, Inc. - S-07-069-10-SC01 - Statement of Charges

On April 11, 2011, the Securities Division entered a Statement of Charges and Notice of Intent to Enter an Order to Cease and Desist, Impose Fines, and Recover Costs against David R. Huetten (“Huetten”) d/b/a DRH Funding, d/b/a DRH Investment Corp., d/b/a DR H One, Inc.  The Statement of Charges alleges that between approximately 2004 and 2006, Huetten raised at least $3 million by offering and selling securities in the form of interests in limited liability companies that were formed as part of various real estate investment programs.  The Statement of Charges alleges that Huetten violated the registration and anti-fraud provisions of the Securities Act of Washington.  The Securities Division intends to order Huetten to cease and desist from violating the Securities Act of Washington, and gives notice of its intent to impose a fine and recover costs.  Huetten has a right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on June 28, 2011.


Corey V. Darling; Wealth Investment Group, LLC - S-10-008-10-SC01 - Statement of Charges

On April 11, 2011, the Securities Division entered a Statement of Charges and Notice of Intent to Enter an Order to Cease and Desist, Deny Future Registrations, Impose Fines and Recover Costs (“Statement of Charges”) against Corey V. Darling (“Darling”) and Wealth Investment Group, LLC (“Wealth Investment Group”) (collectively, “Respondents”). The Statement of Charges alleges that Darling engaged in dishonest and unethical practices while working as a securities salesperson and investment adviser representative, and that these practices are grounds for denial of his future securities registration applications. The Statement of Charges alleges that Darling offered and sold investments in the form of limited liability company membership interests in Wealth Investment Group to four Washington residents, three of whom were securities brokerage customers, and that he offered and sold a promissory note in the amount of $100,000 to another securities brokerage customer. The Statement of Charges alleges that these securities transactions were not recorded on the books and records of the broker-dealer which Darling represented, as required by NASD Conduct Rule 3040. The Statement of Charges further alleges that Darling borrowed money from at least two securities brokerage customers, and by doing so, he failed to comply with FINRA Rule 3240 and engaged in dishonest or unethical practices as defined by WAC 460-22B-090(1). The Statement of Charges alleges that these activities are dishonest and unethical business practices under WAC 460-22B-090 and RCW 21.20.110(1)(g). The Securities Division intends to order the Respondents to each cease and desist from violating the Securities Act of Washington, deny future securities registrations applications of Darling, and impose fines and recover costs. Respondents have the right to request a hearing on the Statement of Charges. 

A Consent Order was entered regarding this matter on May 27, 2011.


R.W. Taylor & Associates, Richard Taylor - S-05-006-07-CO01 - Consent Order

On April 11, 2011, the Securities Division entered into a Consent Order with R.W. Taylor & Associates and Richard Taylor (collectively “Respondents”).  The Securities Division previously issued a Statement of Charges against the Respondents on October 31, 2005.  The Statement of Charges alleged that Taylor offered and sold unregistered investments in Taylor & Associates to at least three Washington state residents and that the Respondents violated the registration and anti-fraud and registration provisions of the Securities Act of Washington.  In settling the matter, the Respondents neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act of Washington.  The Respondents waived their right to a hearing and judicial review of the matter.


Nancy L. Whitney; Gregory J. Caputo - S-08-037-11-CO01 - Consent Order

On March 29, 2011, the Securities Division entered into a Consent Order with Nancy L. Whitney and Gregory J. Caputo.  The Securities Division had previously entered a Statement of Charges and Notice of Intent to Issue an Order to Cease and Desist, Impose Fines, and Charge Costs, S-08-037-10-SC01, against Universal Online, Inc.; J. William Oldenburg; Nancy L. Whitney; and Gregory J. Caputo.  The Statement of Charges alleges that Respondent Oldenburg offered an investment, in the form of a promissory note, to at least two Washington residents.  Respondent Oldenburg raised at least $154,150, purportedly for the development and marketing of the “OPC business system,” a system designed to facilitate the financing of large scale commercial real estate.  The Statement of Charges alleges that Respondents Oldenburg, Whitney, and Caputo made misrepresentations and/or omissions to at least one resident regarding the investment.  Respondents Whitney and Caputo neither admitted nor denied the allegations, but agreed to cease and desist from violating the anti-fraud provision of the Securities Act of Washington.  Respondents Whitney and Caputo waived their right to a hearing and to judicial review of this matter.  The charges against Universal Online, Inc. and J. William Oldenburg are still pending.


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. - S-09-046-11-SC01 - Statement of Charges

On March 29, 2011, the Securities Division 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 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”). The Statement of Charges alleges 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 Statement of Charges alleges 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. 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 collect fines and recover costs. Respondents have a right to request a hearing on the Statement of Charges.

A Consent Order as to James Wynstra was entered on January 30, 2013.

A Consent Order as to Rita Lahman was issued on January 29, 2013


Roger Poon - S-09-187-10-CO01 - Consent Order

On March 23, 2011, the Securities Division entered into a Consent Order with Roger Poon in which the Division alleged that he offered unregistered securities and acted as an unregistered securities broker or salesperson in connection with the offer of a Georgia corporation's stock in 2009. Roger Poon agreed, without admitting or denying the findings of fact, to cease and desist from violating the Securities Act of Washington. Mr. Poon waived his rights to a hearing or other further proceedings in the matter.


William Spencer Howard III;  Raymond Francis Purdon - S-09-154-10-SC01 - Statement of Charges

On March 1, 2011, 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 Recover Costs against William Spencer Howard III and Raymond Francis Purdon (collectively “Respondents”).  The Securities Division alleges 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 alleges 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 alleges 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.  The Securities Division intends to order that the Respondents cease and desist from violating the Securities Act of Washington, and gave notice of its intent to deny future securities registration applications of the Respondents.  The Securities Division also gave notice of its intent to collect fines and charge costs.  The Respondents have a right to request a hearing on the Statement of Charges.

A Consent Order as to William Spencer Howard III was issued on January 11, 2013.

A Final Order was entered against Raymond Francis Purdon on December 21, 2011.


Market4Cast Hedge Fund, LP; Michael George Calhoun - S-09-200-10-SC01 - Statement of Charges

On February 28, 2011, 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 Market4Cast Hedge Fund, LP and Michael George Calhoun (collectively “Respondents”). The Securities Division alleges that Respondent Calhoun offered and sold limited partnership interests in the Market4Cast Hedge Fund, LP, which he operated from his residence on Bainbridge Island, Washington. It is believed that limited partnership interests were sold to at least 12 investors, including at least one Oregon resident. The Securities Division further alleges that by maintaining the hedge fund, Respondent Market4Cast Hedge Fund, LP acted as an investment adviser and Respondent Calhoun acted as an investment adviser representative. The Securities Division alleges that the Respondents offered unregistered securities, acted as unregistered broker-dealers, securities salespersons, investment advisers, and/or investment adviser representatives, and violated the anti-fraud provision of the Securities Act of Washington. The Securities Division intends to order that the Respondents cease and desist from violating the Securities Act of Washington. The Securities Division also gave notice of its intent to collect fines and charge costs. The Respondents have a right to request a hearing on the Statement of Charges.

A Final Order regarding this matter was entered on December 19, 2011.


EQlibrium Corporation, Prime Assets LLC, Paul M. Martinez and Louis A. Pugliese III - S-07-398-11-CO01 – Consent Order

On February 22, 2011, the Securities Division entered into a Consent Order with Respondents, EQlibrium Corporation (“EQlibrium”), Prime Assets LLC, Paul M. Martinez and Louis A. Pugliese III. The Securities Division alleged that EQlibrium, which has its principal place of business in Seattle, Washington, is in the business of offering and selling real estate investments. The Securities Division alleged that from 2007 through 2009, Respondents offered and sold more than $4,800,000 worth of membership interests in Prime Assets LLC for a marina development project and that EQlibrium and Pugliese made an Internet offering of promissory note and deed of trust investments. Without admitting or denying any violations of the Securities Act of Washington, Respondents each agreed to cease and desist from any further violations of RCW 21.10.010, RCW 21.20.040 and RCW 21.20.140. EQlibrium Corporation agreed to pay $3,500 for investigative costs. Respondents each waived their right to an administrative hearing and to judicial review of the Consent Order.


Associated Capital Advance (ACA) LLC and Sandy Hoffman – S-10-258-11-FO01 – Final Order

On February 18, 2011, the Securities Division entered a Final Order against Respondents Associated Capital Advance (ACA) LLC and Sandy Hoffman of Southfield, Michigan. The Securities Division had previously entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist in this matter on September 10, 2010. The Statement of Charges alleged that Respondents solicited $500 from a Washington resident to enable the resident to go into business offering loans. The Statement of Charges further alleged that Respondent offered unregistered business opportunities, failed to comply with disclosure document requirements and violated the anti-fraud provisions of the Business Opportunity Fraud Act. The Securities Division orders Respondents to cease and desist from violating the Business Opportunity Fraud Act.


Beerbaum & Beerbaum Financial and Insurance Services Inc. and Gary D. Lee – S-05-220-11-FO01 – Final Order

On February 18, 2011, the Securities Division entered a Final Order against Respondent Beerbaum & Beerbaum Financial and Insurance Services Inc. (Respondent). The Securities Division had previously entered Summary Order to Cease and Desist and Notice of Intent to Revoke Broker-Dealer Registration, Deny Investment Adviser Registration, Suspend and/or Deny Future Registration, Impose a Fine and Charge Costs (Summary Order) in this matter on January 23, 2006. The Summary Order alleged that Respondent employed a securities salesperson who was not registered in the State of Washington and acted as an unregistered investment adviser. The Securities Division orders Respondent to Cease and Desist from violating the registration provisions of the Securities Act, revokes Respondent's broker-dealer registration and denies Respondent's investment adviser registration application. Respondent has a right to request judicial review of the Final Order.


Westgate Advisors, Inc.; Thomas Signorelli - S-10-333-11-SC01 - Statement of Charges

On February 18, 2011, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist against Westgate Advisors d/b/a Westgate Business Finance and its President, Thomas Signorelli (collectively, “Respondents”).  Respondents sold a business opportunity involving training and support services in the origination of business debt transactions for small businesses. The Statement of Charges alleges that Respondents offered and sold this business opportunity to at least one Washington resident while not registered to do so under the Business Opportunity Fraud Act of Washington (the “Act”).  The Statement of Charges also alleges that Respondents failed to provide material information and disclosure documents concerning the business opportunity. The statement of charges further alleges that the Respondents violated the Act’s anti-fraud provision. Respondents have a right to request a hearing on the Statement of Charges.

A Consent Order was entered in this matter on June 9, 2011.


Vannox Diversified Entertainment, Inc. d/b/a Astro Jump and Astro Events - S-09-374-11-SC01 - Statement of Charges

On February 18, 2011, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist against Vannox Diversified Entertainment, Inc. d/b/a Astro Jump and Astro Events (“Astro Jump”). The Statement of Charges alleges that Astro Jump offered and sold a franchise in the State of Washington that had not been registered with the Securities Administrator. The Statement of Charges further alleges that Astro Jump failed to provide the Washington purchaser with the required Franchise Disclosure Documents containing all material information about the franchise. The Securities Division intends to order the Respondents to cease and desist from violations of the Franchise Investment Protection Act. Astro Jump has the right to request a hearing on the Statement of Charges.

A Consent Order was entered in this matter on May 4, 2011.


Morrie Friedman - S-07-028-11-FO01 - Final Order

On February 18, 2011, the Securities Division entered a Final Order against Morrie Friedman ("Respondent").  The Securities Division previously entered a Statement of Charges against the Respondent on June 29, 2007.  The Statement of Charges alleged that the Respondent raised at least $10,000 from one or more Washington residents, by offering and selling unregistered preferred and common stock in Beyond Juice, Inc., a nutrition based fast food restaurant chain. The Securities Division alleged that the Respondent violated the anti-fraud and registration provisions of the Securities Act of Washington.  The Securities Division orders the Respondent to cease and desist from violating the Securities Act of Washington, and orders the Respondent to pay a fine of $10,000.  The Respondent has a right to request judicial review of the Final Order.


Robert Malecki, Homeowner Resources LLC, Kitsap Private Lending Group LLC - S-08-347-10-CO01 - Consent Order

On January 20, 2011, the Securities Division entered into a Consent Order with Robert Malecki, Homeowner Resources LLC, and Kitsap Private Lending Group LLC (“Respondents”).  The Securities Division had previously issued a Statement of Charges against Respondents on February 2, 2010.  The Statement of Charges alleged that Respondents offered and sold investments in the form of private mortgage loans to multiple lenders on the same property.  The Statement of Charges further 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, Respondents neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act of Washington.  Respondents waived their right to a hearing and to judicial review of this matter and Robert Malecki agreed to pay costs of $4,000.


Robert Pecord and Capital Asset Group, LLC - S-08-181-10-CO01 - Consent Order

On January 12, 2011, the Securities Division entered into a Consent Order, S-08-181-10-CO01, with Capital Asset Group, LLC and Robert Pecord. Previously, on August 11, 2008, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist and to Impose Fines and Charge Costs against Robert Edwards d/b/a E-Z Unlimited, Robert Pecord, and Capital Asset Group, LLC (collectively “Respondents”). Capital Asset Group purportedly engaged in the business of foreign exchange asset management. The Statement of Charges alleged that Respondents offered and sold investments in the form of promissory notes to at least one Washington resident. Respondents raised at least $100,000. The Statement of Charges further alleged that Respondents offered unregistered securities and acted as unregistered broker-dealers or securities salespersons. The Statement of Charges additionally alleged that the offer and sale of securities by Respondents violated the anti-fraud provisions of the Securities Act of Washington. In settling the matter, Respondents Capital Asset Group and Robert Pecord agreed, without admitting or denying the findings of fact, to cease and desist from violating the Securities Act of Washington. Respondents Capital Asset Group and Robert Pecord waived their rights to a hearing or other further proceedings in the matter.


Charles Jean Guzek - S-09-446-11-FO01 - Final Order

On January 12, 2011, the Securities Division entered a Final Order against Respondent Charles Jean Guzek (“Respondent”). The Securities Division had previously entered Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, Impose Fines, and Charge Costs (“Statement of Charges”) in this matter on November 9, 2010. The Statement of Charges alleged that Respondent solicited $10,000 from a Washington resident, which Respondent claimed he would invest in the foreign exchange market. The Statement of Charges further alleged that Respondent offered unregistered securities, acted as an unregistered securities salesperson, and violated the anti-fraud provisions of the Securities Act of Washington. The Securities Division orders Respondent to cease and desist from violating the Securities Act of Washington. The Securities Division further orders Respondent to pay a fine of $5,000 and investigative costs of $1,500. Respondent has a right to request judicial review of the Final Order.


Traderight Corp. dba Traderight Securities, Inc. - S-08-211-10-CO01 - Consent Order

On January 11, 2011, the Securities Division entered into a Consent Order, S-08-211-10-CO01, with Traderight Corp. dba Traderight Securities, Inc. (“Traderight Securities”).  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-08-211-09-SC01, against Tradeology.com, Inc.; Traderight Corp. dba Traderight Securities, Inc.; and Jygnesh Rohit Patel on August 26, 2010.  The Statement of Charges alleged that approximately ten Washington residents were sold stock in Tradeology.com, Inc., a start-up online stock trading company located in Florida.  Subsequently, Respondent Patel told the residents that he arranged for their stock in Tradeology.com, Inc. to be exchanged for stock in Traderight Securities, a company he had acquired.  It is believed that this exchange never occurred.  After Tradeology.com, Inc. went out of business, Respondent Patel presented two additional stock offerings to at least two of the residents as a means to recoup losses incurred from their investment in the company.  The Statement of Charges further alleged that certain Respondents offered unregistered securities, acted as unregistered broker-dealers or securities salespersons, and violated the anti-fraud provision of the Securities Act of Washington.  Respondent Traderight Securities neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act.  Respondent Traderight Securities waived its right to a hearing and to judicial review of this matter.


Philip Boos - S-09-163-10-CO02 - Consent Order

On January 3 , 2011, the Securities Division entered into a Consent Order, S-09-163-10-CO02, with Philip Boos. Previously, on May 21, 2010, the Securities Division entered a Statement of Charges, S-09-163-10-SC01, against NDG Investment Group, LLC (NDG), Mr. Boos 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. Boos, a former NDG employee, agreed, without admitting or denying the findings of fact, to cease and desist from violating the Securities Act of Washington. Mr. Boos waived his rights to a hearing or other further proceedings in the matter.


PortraitEFX Franchising Corporation - S-10-241-10-CO01 - Consent Order

On January 3, 2011, the Securities Division entered into a Consent Order with PortraitEFX Franchising Corporation, a Texas corporation, in settlement of the Division’s allegations of a franchise law violation by the company. PortraitEFX Franchising Corporation is in the business of offering professional photography services franchises. The Division alleged in the Consent Order that the company had failed to comply with the registration provision of the Franchise Investment Protection Act. PortraitEFX Franchising Corporation agreed, without admitting or denying the findings of fact, to cease offering or selling franchises in violation of the registration provision of the Franchise Act. PortraitEFX Franchising Corporation agreed to reimburse the Securities Division $1,400 for its costs of investigation. PortraitEFX Franchising Corporation also waived its right to a hearing or other further proceedings in the matter.

DFI