2016 Division of Securities Enforcement Actions

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Binary Banc – S-16-2012-16-FO01 - Final Order

On December 23, 2016, the Securities Division entered a Final Order against Binary Banc, which operates an online trading platform for binary option traders. The Securities Division had previously entered a Statement of Charges against the Respondents alleging that Binary Banc violated the anti-fraud provisions of the Securities Act of Washington when it solicited Washington resident through emails and telephone calls and causing him to incur more than $67,000 in debit card and credit card charges. The Final Order orders Binary Banc to cease and desist from violating the Securities Act of Washington, to reimburse the Securities Division for its investigative costs, and to pay a fine. Binary Banc has the right to seek judicial review of the Final Order.


Big Spring Gold, LLC and Louis A. Christensen – S-16-2078-16-SC01 - Statement of Charges

On December 23, 2016, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Impose a Fine, and to Charge Costs (“Statement of Charges”) against Respondents, Big Spring Gold, LLC (“Big Spring”) and Louis A. Christensen (“Christensen”). The Securities Division alleged that Big Spring and Christensen had violated the registration and anti-fraud provisions of the Securities Act of Washington when offering and selling LLC membership interests. The Statement of Charges gives notice of the Securities Division’s intent to order the Respondents to cease and desist from violations of the Securities Act of Washington and to impose a fine and charge costs. The Respondents each have the right to request a hearing on the Statement of Charges.

A Consent Order as to Big Spring Gold was entered on March 2, 2017.

A Consent Order as to Louis Christensen was entered on March 2, 2017.


Raymond Willis; MiniHYA Corporation – S-15-1624-16-FO01 – Final Order

On November 16, 2016, the Director of the Washington Department of Financial Institutions entered a Final Order against Raymond Willis and MiniHYA Corporation (“Respondents”). In the Final Order, the Securities Division found that Respondents violated RCW 21.20.010 and RCW 21.20.140, the anti-fraud and registration sections, respectively, of the Securities Act of Washington (the “Act”). It further found that Willis violated RCW 21.20.041 by selling securities while unregistered as a securities salesperson or broker-dealer in Washington. The Final Order ordered Respondents to cease and desist from any further violations of RCW 21.20.010 and RCW 21.20.140. It also ordered Willis to cease and desist from any further violations of RCW 21.20.040. Finally, the Final Order ordered Respondents to pay fines of $30,000 and to pay investigative costs of $7,000. The Respondents have the right to petition the superior court for judicial review of the Final Order.


Donald Charles Sukin d.b.a. MBA Business Brokers - S-15-1651-16-FO01 - Final Order

On November 10, 2016, the Securities Division entered a Final Order to Cease and Desist against Respondent Donald Charles Sukin (“Sukin”) d.b.a. MBA Business Brokers. The Securities Division issued a Statement of Charges on November 10, 2015, alleging that Sukin violated the Franchise Investment Protection Act by offering franchises in Washington while not registered as a franchise broker. The Division also alleged that Sukin misrepresented and failed to disclose material facts in connection with the offer of a franchise. The Final Order orders Sukin to cease and desist from future violations of RCW 19.100.140 and RCW 19.100.170, the franchise broker registration and anti-fraud portions of the Franchise Investment Protection Act. Respondent has a right to seek judicial review of the Final Order.


Binary Banc - S-16-2012-16-SC01 – Statement of Charges

On November 7, 2016, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Impose a Fine, and to Charge Costs (“Statement of Charges”) against Binary Banc, which operates an online trading platform for binary option traders. The Statement of Charges alleges that the Binary Banc violated the anti-fraud provisions of the Securities Act of Washington by soliciting a Washington resident through emails and telephone calls and causing him to incur more than $67,000 in debit card and credit card charges. The Securities Division intends to order Binary Banc to cease and desist from violating the Securities Act of Washington and gives notice of its intent to impose a fine and to charge costs. Binary Banc has a right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on December 23, 2016.


Rent-A-Ruminant, LLC, Rent-A-Ruminant Franchise, LLC, and Tammy Dunakin - S-16-1973-16-CO01 – Consent Order

On October 31, 2016, the Securities Division entered into a Consent Order with Respondents Rent-A-Ruminant, LLC, Rent-A-Ruminant Franchise, LLC, and Tammy Dunakin (“the Respondents”). The Securities Division had previously alleged in Statement of Charges S-16-1973-16-SC01 that the Respondents offered and/or sold franchises to Washington residents in violation of state franchise law. The Division alleged that Respondents violated the Franchise Investment Protection Act by offering and selling franchises in the form of affiliate/licenses in Washington while not registered to do so. Respondents failed to provide prospective franchisees with a franchise disclosure document containing material information about the investment opportunity. Without admitting or denying the Securities Division’s allegations, the Respondents agreed to cease and desist from violations of RCW 19.100.020 and RCW 19.100.080, the registration and disclosure document portions of the Franchise Investment Protection Act. Respondents also agreed to pay investigative costs of 500.00 and waived their right to a hearing and judicial review of the matter.


Jeanne Christensen and Doing Business, Inc. - S-13-1218-16-FO01 – Final Decision and Order

On October 28, 2016, the Securities Division entered a Final Decision and Order against Jeanne Christensen and Doing Business, Inc.

Previously, on June 12, 2014, the Securities Division issued a Statement of Charges against Jeanne Christensen and Doing Business, Inc. The Statement of Charges alleged that Jeanne Christensen and Doing Business, Inc. violated the registration and the anti-fraud provisions of the Securities Act of Washington in connection with their operation of a fraudulent high-yield investment program.

The Office of Administrative Hearings (OAH), on June 23, 2016, issued an Initial Order on Respondents’ Motion to Dismiss and Department’s Summary Judgment Motion (Initial Order). In the Initial Order, OAH affirmed the conclusions of law and the listed penalties in the Statement of Charges.

After reviewing Jeanne Christensen’s and Doing Business, Inc.’s Petition for Review of the Initial Order, in its Final Decision and Order, the Securities Division affirmed findings of fact, conclusions of law, and listed penalties in the Initial Order.

Both Jeanne Christensen and Doing Business, Inc. each have a right to seek judicial review of the Final Decision and Order.


Ecocruise Electric Transportation, Inc. and Steven D. Leighty - S-16-1945-16-SC01 - Statement of Charges

On October 27, 2016, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to impose a Fine, and to Charge Costs (“Statement of Charges”) against Respondents, Ecocruise Electric Transportation, Inc. (“Ecocruise”) and Steven D. Leighty (“Leighty”).

Ecocruise had its principal place of business in Seattle, Washington and was developing and producing electric vehicles. From at least August 2011 through July 2015, the Respondents offered and sold at least $480,000 worth of Ecocruise stock to at least ten investors. The Statement of Charges alleges that the Respondents offered and sold unregistered securities and misrepresented or misleadingly omitted material information when offering and selling Ecocruise stock to investors.

The Statement of Charges gives notice of the Securities Division’s intent to order the Respondents to cease and desist from violations of the Securities Act of Washington and to impose a fine and charge costs. The Respondents each have the right to request a hearing on the Statement of Charges.


Steven Eugene Ling – S-12-1065-16-FO01 – Final Order

On October 26, 2016, the Director of the Washington Department of Financial Institutions entered a Final Order against Steven Eugene Ling (“Respondent”). The Final Order orders Respondent to cease and desist from any further violations of RCW 21.20.010. The Final Order also orders Respondent to pay a fine of $10,000 and to pay investigative costs of $1,000. The Respondent has the right to petition the superior court for judicial review of the Final Order.


Thomas Madden – S-14-1463-16-CO01 – Consent Order

On October 21, 2016, the Securities Division entered into a Consent Order with Respondent Thomas Madden.

The Securities Division had previously entered a Statement of Charges against Thomas Madden alleging that he engaged in fraudulent conduct and acted as an unregistered securities broker-dealer in his sale of stock to Washington residents.

In the Consent Order, Thomas Madden admitted to the order’s Findings of Fact and Conclusions of Law. As part of the Consent Order, Thomas Madden also agreed to cease and desist from violating the Securities Act of Washington, pay $8,000 in investigative costs, and pay $4,000 in fines. Thomas Madden waived his right to a hearing and judicial review of this matter.


ATNCare Franchising LLC d/b/a Go Telecare; Dipak Nandi – S-15-1747-16-CO01 – Consent Order

On October 20, 2016 the Securities Division entered Consent Order S-15-1747-16-CO01 with ATNCare Franchising LLC d/b/a Go Telecare and Dipak Nandi (collectively “the Respondents”). In the Consent Order, the Securities Division alleged that the Respondents had violated the Franchise Act of Washington by falsely stating in a September 2015 franchise registration renewal application that they had not sold any Washington-based franchises, when in fact they had sold a Washington franchise approximately three months earlier. Without admitting or denying the Securities Division’s allegations, the Respondents agreed to cease and desist from violating the Franchse Act and to pay $1,000 in investigative costs. The Respondents agreed to waive their right to a hearing and judicial review of the matter.


UCI Wealth Advisors, LLC and Travis Higgins - S-16-2049-16-SC01 - Statement of Charges

On October 3, 2016 the Securities Division entered into a Statement of Charges S-16-2049-16-SC01 stating that UCI Wealth Advisors, LLC (CRD # 0154884) (UCI) and Travis Higgins (CRD # 04460566) are subject to a Consent Order and Stipulation by the Colorado Securities Administrator that revoked the investment adviser registration of UCI and the investment adviser representative registration of Higgins. The Statement of Charges gave notice of the Securities Division’s intent to revoke the investment adviser registration of UCI and the investment adviser representative registration of Higgins. The Statement of Charges also gave notice of the intent to impose a fine of at least $1,000 to each respondent and charge costs of $100. Respondents have a right to request a hearing in the matter.

A Consent Order was entered regarding this matter on March 3, 2017.


Research Money Management, LLC and Jason Bescoe – S-15-1698-16-FO01 – Final Order

On August 31, 2016, the Securities Division entered a Final Order S-15-1698-16-FO01 against Research Money Management (CRD #141298) and Jason Bescoe (CRD #2603245) (collectively “Respondents”). The Securities Division issued a Statement of Charges on July 18, 2016, alleged that RMM violated RCW 21.20.040(3) by transacting business in Washington state as an investment adviser when it was not so registered in Washington and violated RCW 21.20.040(5) by associating with an investment adviser representative that was not so registered. The Statement of Charges further alleged that Mr. Bescoe violated RCW 21.20.040 by transacting business in Washington State as an investment adviser representative while not being so registered. The Final Order orders Respondents to cease and desist from violating the Securities Act and to pay a fine and costs. Respondents have a right to seek judicial review of the Final Order.


James Lisowsky – S-15-1672-16-FO01 – Final Order

On August 29, 2016, the Securities Division entered a Final Order against James Lisowsky (“Lisowsky”). The Securities Division previously entered a Statement of Charges against Lisowsky and other Respondents on August 1, 2016. The Statement of Charges alleged that Lisowsky took part in raising over $600,000 for SoloMatrix, Inc., a cell phone accessory company, through the sale of various unregistered debt instruments and common stock. The Securities Division further alleged that Lisowsky was not registered to solicit such investments and made material misrepresentations or omissions in the offer and sale of the securities. The Final Order orders Lisowsky to cease and desist from violating the Securities Act of Washington, to pay a fine of $7,500, and to pay investigative costs of $1,000. Lisowsky has the right to request judicial review of the Final Order.


Kirtan Khalsa – S-15-1768-16-CO01 – Consent Order

On August 23, 2016, the Securities Division entered a Consent Order with Kirtan Khalsa (“Khalsa”). The Securities Division previously entered a Statement of Charges and Notice of Intent to Issue an Order to Cease and Desist, Impose Fines, and Recover Costs against Ascension Energy Group, Inc.; Sequoia Energy Project LLLP; Matthew D. Ehrhardt a/k/a Danny Ehrhardt; Lon E. Stein; Michael F. Camacho; Khalsa, and Elvis R. Mendes a/k/a Ron Mendes. The Securities Division alleged that Khalsa, among others, violated RCW 21.20.010, RCW 21.20.040, and RCW 21.20.140,in connection with the offer and sale of oil and gas investments. Without admitting or denying the Securities Division’s allegations, Khalsa has agreed to cease and desist from violating the Securities Act of Washington. Khalsa agreed to pay a fine of $1,000 and costs of $100. Khalsa waived his right to a hearing and judicial review of this matter.


Chadwick B. King – S-12-0994-16-FO02 – Final Order

On August 23, 2016, the Securities Division entered a Final Order against Chadwick B. King.

The Securities Division had previously entered a Statement of Charges against Chadwick B. King and Sarah Louthan a/k/a Cerah Bennett alleging that they violated the Securities Act of Washington through their operation of a fraudulent high-yield investment scheme.

The Final Order orders Chadwick B. King to cease and desist from further violations of the Securities Act of Washington and to pay the listed fines and costs. Chadwick B. King has the right to request judicial review of the Final Order.


Alpha Martial Arts, LLC and Christopher Herrman - S-16-2006-16-CO01 - Consent Order

On August 23, 2016, the Securities Division entered into a Consent Order with Respondents Alpha Martial Arts, LLC and Christopher Herrman. The Securities Division alleged that the Respondents offered and/or sold a franchise located in Washington in violation of state franchise law. The Division alleged that the Respondents violated the Franchise Investment Protection Act by offering and selling franchises in Washington while not registered to do so and failing to provide a franchise disclosure document to a prospective purchaser. Without admitting or denying the Securities Division’s allegations, Respondents agreed to cease and desist from violations of RCW 19.100.020 and RCW 19.100.080, the franchise registration and disclosure document sections of the Franchise Investment Protection Act. The Respondents agreed to reimburse the Securities Division for investigative costs of $1,200 and waived their right to a hearing and judicial review of the matter.


Astral Health & Beauty, Inc. f/k/a Aloette Cosmetics, Inc. – S-16-1979-16-CO01 – Consent Order

On August 9, 2016 the Securities Division entered into a Consent Order with Astral Health & Beauty, Inc. f/k/a Aloette Cosmetics, Inc. (“Respondent”). The Securities Division alleged that Respondent violated the registration provision of the Franchise Investment Protection Act of Washington. Without admitting or denying the Securities Division’s allegations, Respondent agreed to cease and desist from violations of RCW 19.100.020. The Respondent agreed to reimburse the Securities Division for investigative costs of $1,000 and waived its right to a hearing and judicial review of this matter.


Lori Cousineau Weaver - S-14-1575-16-CO01 – Consent Order

On August 9, 2016, the Securities Division entered into a Consent Order with Lori Cousineau Weaver (“Cousineau Weaver”). The Securities Division previously entered a Statement of Charges against Cousineau Weaver on February 23, 2016. The Statement of Charges alleged Cousineau Weaver offered and sold non-traded real estate investment trusts (“REITs”) to customers, including many senior citizens, through unsuitable recommendations and failed to disclose complete information regarding the fees, commissions, and illiquidity of these products.

In settling the matter, Cousineau Weaver neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act. Cousineau Weaver further agreed to pay a fine of $100,000 and to reimburse the Securities Division $10,000 for its costs of investigation. Cousineau Weaver agreed to a 30 day suspension from registration as a securities salesperson. Cousineau Weaver waived her right to a hearing and to judicial review of the matter.


Little Loan Shoppe Ltd.; Little Loan Shoppe America, LLC; 639504 BC, Ltd.; Little Loan Shoppe Canada, LLC; 0738116 BC, Ltd.; LLS America, LLC; LLS-A, LLC (WA); Pacific LLS, LLC; Atlantic LLS, LLC; Eastern LLS, LLC; Central LLS, LLC; LLS-A, LLC (NV); LLS-NW, LLC; LLS-US, LLC; and Doris Nelson – S-09-216-15-CO01 – Consent Order

On August 8, 2016, the Securities Division entered into a Consent Order with Little Loan Shoppe Ltd.; Little Loan Shoppe America, LLC; 639504 BC, Ltd.; Little Loan Shoppe Canada, LLC; 0738116 BC, Ltd.; LLS America, LLC; LLS-A, LLC (WA); Pacific LLS, LLC; Atlantic LLS, LLC; Eastern LLS, LLC; Central LLS, LLC; LLS-A, LLC (NV); LLS-NW, LLC; LLS-US, LLC; and Doris Nelson (“Respondents”).

The Securities Division previously entered a Statement of Charges against Respondents on January 28, 2010. The Statement of Charges alleged that Respondents raised over $29 million U.S. dollars and $26 million Canadian dollars from at least 300 investors through the sale of unregistered promissory notes. The Statement of Charges further alleged that Respondents claimed the funds would be used to fund the operations and expansion of a payday/installment loan company. 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. 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.


Matthew D. Ehrhardt - S-15-1768-16-FO02 – Final Order

On August 5, 2016, the Securities Division entered a Final Order to Cease and Desist, Impose Fines, and Recover Costs as to Matthew D. Ehrhardt a/k/a/ Danny Ehrhardt (Ehrhardt).

In the Final Order, the Securities Division finds that Ehrhardt violated RCW 21.20.010, the antifraud provision of the Securities Act, by misrepresenting or failing to disclose material information in connection with the sale of partnership interests in Sequoia, an oil and gas project. The Securities Division further finds that Ehrhardt violated RCW 21.20.140, the unregistered securities provision of the Securities Act, by selling unregistered securities, for which no valid claim of exemption existed, to Washington residents. Finally, the Securities Division finds that Ehrhardt violated RCW 21.20.040 by selling securities while unregistered as a securities salesperson or broker-dealer in Washington. The Securities Division orders Ehrhardt to cease and desist from violating the Securities Act of Washington, to pay fines, and to pay investigative costs. Ehrhardt has a right to request judicial review of this matter.


Scott B. Wilkerson and WebRotator, Inc. – S-15-1702-16-CO01 – Consent Order

On August 5, 2016, the Securities Division entered into a Consent Order with Scott B. Wilkerson and WebRotator, Inc (“Respondents”). The Securities Division alleged that Respondents each violated RCW 21.20.140 by offering and selling more than $2.5 million worth of unregistered stock to more than 100 investors and that Scott B. Wilkerson violated RCW 21.20.040 by offering and selling stock while not being registered as a securities broker-dealer or salesperson. The Securities Division also alleged that Respondents each violated RCW 21.20.010, the anti-fraud section of the Securities Act of Washington, by making materially misleading statements or by failing to disclose material information. Without admitting or denying the Securities Division’s allegations, the Respondents each agreed to cease and desist from any violation of RCW 21.20.010 and RCW 21.20.140 and Scott B. Wilkerson agreed to cease and desist from any violation of RCW 21.20.040, to pay a fine of $25,000, and to pay costs of $5,000. The Respondents each waived their right to a hearing and judicial review of this matter. The Securities Division previously entered a statement of charges.


Donald Wells – S-14-1603-16-CO03 – Consent Order

On August 2, 2016, the Securities Division entered into a Consent Order with Respondent Donald Wells. The Securities Division previously entered a Statement of Charges against Wells and various other respondents on March 7, 2016.

In the Statement of Charges, the Securities Division alleged that Wells violated the securities registration, securities salesperson, and antifraud provisions of the Securities Act of Washington in the offer and sale of Life Partners, Inc. life settlements. Without admitting or denying the Securities Division’s allegations, Wells agreed to cease and desist from violating the Securities Act of Washington, to pay a fine of $2,450, and to pay investigative costs of $250. Wells waived his right to a hearing and judicial review of this matter.


Rent-A-Ruminant, LLC, Rent-A-Ruminant Franchise, LLC, and Tammy Dunakin - S-16-1973-16-SC01 – Statement Of Charges

On August 2 , 2016, the Securities Division entered a Statement of Charges against Respondents Rent-A-Ruminant, LLC, Rent-A-Ruminant Franchise, LLC, and Tammy Dunakin. The Securities Division alleges that the Respondents offered and/or sold franchises to Washington residents in violation of state franchise law. The Division alleges that Respondents violated the Franchise Investment Protection Act by offering and selling franchises in the form of affiliate/licenses in Washington while not registered to do so. Respondents failed to provide prospective franchisees with a franchise disclosure document containing material information about the investment opportunity. The Securities Division intends to order the Respondents to cease and desist from violations of RCW 19.100.020 and RCW 19.100.080, the franchise registration and disclosure document sections of the Franchise Investment Protection Act. The Respondents each have an opportunity for hearing in this matter.

A Consent Order was entered regarding this matter on October 31, 2016.


SoloMatrix, Inc.; Robert Solomon; James Lisowsky – S-15-1672-16-SC01 – Statement of Charges

On August 1, 2016, the Securities Division entered Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, To Impose Fines and Charge Costs against SoloMatrix, Inc.; Robert Solomon, and James Lisowsky (collectively “Respondents”). The Securities Division alleges that Respondents raised over $600,000 for SoloMatrix, Inc., a cell phone accessory company, through the sale of various unregistered debt instruments and common stock. The Securities Division further alleges that SoloMatrix used an unregistered salesperson to solicit some of the investments and that the Respondents made material misrepresentations or omissions in the offer and sale of the securities. The Securities Division intends to order Respondents to cease and desist from violating the Securities Act of Washington, and gives notice of its intent to impose fines and charge costs. The Respondents have a right to request a hearing on the Statement of Charges.

A Consent Order as to SoloMatrix, Inc. and Robert Solomon was entered on March 3, 2017.

A Final Order as to James Lisowsky was entered on August 29, 2016.


Life Partners, Inc. & Life Partners Holdings, Inc. – S-14-1603-16-CO04 – Consent Order

On July 18, 2016, the Securities Division entered into a Consent Order with Respondents Life Partners, Inc. and Life Partners Holdings, Inc. (“LPI” and “LPHI” respectively). The Securities Division previously entered a Statement of Charges against LPI, LPHI, and various other respondents on March 7, 2016.

In the Statement of Charges, the Securities Division alleged that LPI and LPHI violated the securities registration and antifraud provisions of the Securities Act of Washington in the offer and sale of life settlements. Without admitting or denying the Securities Division’s allegations, LPI and LPHI agreed to cease and desist from violating the Securities Act of Washington. LPI and LPHI waived their right to a hearing and judicial review of this matter.


Tim Watters – S-14-1603-16-CO12 – Consent Order

On July 18, 2016, the Securities Division entered into a Consent Order with Respondent Tim Watters (“Watters”). The Securities Division previously entered a Statement of Charges against Watters and various other respondents on March 7, 2016.

In the Statement of Charges, the Securities Division alleged that Watters violated the securities registration, securities salesperson, and antifraud provisions of the Securities Act of Washington in the offer and sale of Life Partners, Inc. life settlements. Without admitting or denying the Securities Division’s allegations, Watters agreed to cease and desist from violating the Securities Act of Washington, to pay a fine of $3,600, and to pay investigative costs of $250. Watters waived his right to a hearing and judicial review of this matter.


Working Capital for Community Needs, Inc. – S-16-1963-16-CO01 – Consent Order

On July 18, 2016, the Securities Division entered a Consent Order with Working Capital for Community Needs, Inc. (WCCN). The Securities Division alleged that in the issuance of some of its promissory notes, WCCN did not comply with the Security Act of Washington’s nonprofit exemption from registration.

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


Research Money Management and Jason Bescoe - S-15-1698-16-SC01 - Statement of Charges

On July 18, 2016, the Securities Division entered into a Statement of Charges S-15-1698-16-SC01 against Research Money Management (CRD #141298) and Jason Bescoe (CRD #2603245) (collectively “Respondents”). The Statement of Charges alleges that RMM violated RCW 21.20.040(3) by transacting business in Washington state as an investment adviser when it was not so registered in Washington and violated RCW 21.20.040(5) by associating with an investment adviser representative that was not so registered. The Statement of Charges further alleges that Mr. Bescoe violated RCW 21.20.040 by transacting business in Washington state as an investment adviser representative while not being so registered. The Statement of Charges orders Respondents to cease and desist and pay a fine and costs. Respondents have a right to a hearing on the matter.

A Final Order was entered regarding this matter on August 31, 2016.


Travis Moegling; Yellowstone Capital, LLC; Bainbridge Views, LLC; Imperium Builder, LLC - S-16-1870-16-FO01 – Final Order

On July 5, 2016, the Securities Division entered a Final Order against Travis Moegling; Yellowstone Capital, LLC; Bainbridge Views, LLC; Imperium Builder, LLC (“Respondents”). The Securities Division previously issued a Summary Order, which alleged that the Respondents violated the anti-fraud provisions of the Securities Act of Washington through the sale of promissory note investments that were secured by deeds of trust. The Final Order orders the Respondents to cease and desist from violating the Securities Act of Washington, to reimburse the Securities Division for its investigative costs, and to pay fines. The Respondents have the right to seek judicial review of the Final Order.


Iverson Genetic Diagnostics, Inc. – S-14-1415-16-FO04 - Final Order

On June 28, 2016, the Securities Division entered a Final Order against Iverson Genetic Diagnostics, Inc. (“Iverson”). The Securities Division previously entered a Statement of Charges against Iverson and other Respondents on April 26, 2016. The Statement of Charges alleged that Iverson, a genetic testing company, raised over $19 million through the sale of unregistered common stock and convertible debt. The Securities Division further alleged that Iverson used unregistered salesperson to solicit such investments and made material misrepresentations or omissions in the offer and sale of the securities. The Final Order orders Iverson to cease and desist from violating the Securities Act of Washington. The Final Order orders Iverson to pay a fine of $60,000 and to pay investigative costs of $10,000. Iverson has the right to request judicial review of the Final Order.


Andrew W. Morrison; Path Investments Group, LLC; CityGuru, Inc. f/k/a On The Go Technologies, Inc. - S-15-1785-16-SC01 - Statement of Charges

On June 27, 2016, 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 Andrew W. Morrison, Path Investments Group, LLC and CityGuru, Inc. f/k/a On The Go Technologies, Inc. (collectively “Respondents”). The Statement of Charges alleges that the Respondents raised more than $180,000 by offering and selling investments in Path Investments Group, On The Go, and CityGuru to at least ten investors, including two Washington residents. The Statement of Charges alleges that Respondent Morrison acted as an unregistered broker-dealer and/or securities salesperson and that several of the offerings were unregistered. The Statement of Charges also alleges that the offer and sale of securities by the Respondents violated the anti-fraud provision of the Securities Act of Washington. The Securities Division ordered the Respondents to cease and desist from violating the Securities Act of Washington, and gave notice of its intent to collect fines and charge costs. Respondents have a right to request a hearing on the Statement of Charges.


Kim Butler; Partners Portfolio Solutions, Inc. – S-14-1603-16-CO11 – Consent Order

On June 27, 2016 the Securities Division entered into a Consent Order with Respondents Kim Butler (“Butler”) and Partners Portfolio Solutions, Inc. (“PPS”). The Securities Division previously entered a Statement of Charges against Butler, PPS, and various other respondents on March 7, 2016.

In the Statement of Charges, the Securities Division alleged that Butler and PPS violated the securities registration, securities salesperson, and antifraud provisions of the Securities Act of Washington in the offer and sale of Life Partners, Inc. life settlements. Without admitting or denying the Securities Division’s allegations, Butler and PPS agreed to cease and desist from violating the Securities Act of Washington, to pay a fine of $1,950, and to pay investigative costs of $250. Butler and PPS waived their right to a hearing and judicial review of this matter.


Perma Treat, Inc. and Terry Alan Rennie - S-16-1857-16-CO01 - Consent Order

On June 22, 2016, the Securities Division entered a Consent Order with Respondents Perma Treat, Inc. and Terry Alan Rennie of Bend, Oregon. The Securities Division entered a Statement of Charges against Respondents Perma Treat, Inc. and Terry Alan Rennie on April 26 , 2016. The Securities Division alleged that the Respondents offered and/or sold a franchise in the form of a joint venture agreement to a Washington resident in violation of state franchise law. The Division alleged that Respondents violated the Franchise Investment Protection Act by offering and selling franchises in Washington while not registered to do so and failed to provide a prospective franchisee with a franchise disclosure document with material information about the franchise offering. Without admitting or denying the Securities Division’s allegations, Respondents agreed to cease and desist from violations of RCW 19.100.020 and RCW 19.100.080, the registration and disclosure document portions of the Franchise Investment Protection Act. Respondents Perma Treat, Inc. and Terry Alan Rennie agreed to pay investigative costs of $3,000 and waived their right to a hearing and judicial review of the matter.


Dean A. Esposito; Joseph DeVito; Viper Asset Management, LLC; DJC Consulting LLC – S-14-1415-16-FO03 - Final Order

On June 17, 2016, the Securities Division entered a Final Order against Dean A. Esposito (“Esposito”); Joseph DeVito (“DeVito”); Viper Asset Management, LLC (“Viper”); and DJC Consulting LLC (“DJC”). The Securities Division previously entered a Statement of Charges against Esposito, DeVito, Viper, DJC, and other Respondents on April 26, 2016. The Statement of Charges alleged that Esposito, DeVito, Viper, and DJC took part in raising over $19 million for Iverson Genetic Diagnostics, Inc., a genetic testing company, through the sale of unregistered common stock and convertible debt. The Securities Division further alleged that Esposito, DeVito, Viper, and DJC were not registered to solicit such investments and made material misrepresentations or omissions in the offer and sale of the securities. The Final Order orders Esposito, DeVito, Viper, and DJC to cease and desist from violating the Securities Act of Washington. The Final Order orders Esposito to pay a fine of $30,000 and DeVito to pay a fine of $30,000. The Final Order orders Esposito to pay investigative costs of $1,000 and DeVito to pay investigative costs of $1,000. Esposito, DeVito, Viper, and DJC have the right to request judicial review of the Final Order.


Josh J. Murakami; GoTradeSignals - S-15-1626-15-SC01 - Statement of Charges

On June 16, 2016, 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 Josh J. Murakami and GoTradeSignals (collectively “Respondents”). The Statement of Charges alleges that the Respondents are disseminating a subscription-based newsletter with specific options trading instructions to investors with auto-traded accounts. The Statement of Charges further alleges that Murakami failed to fully disclose his history of prior enforcement actions to all newsletter subscribers. The Statement of Charges alleges that the Respondents are acting as an unregistered investment adviser and investment adviser representative and have violated the investment adviser anti-fraud provision of the Securities Act of Washington. The Securities Division ordered the Respondents to cease and desist from violating the Securities Act of Washington, and gave notice of its intent to collect fines and charge costs. Respondents have a right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on March 7, 2019.


David Baer - S-16-1853-16-FO02 – Final Order

On June 15, 2016, the Securities Division entered a Final Order against Respondent David Baer of Portland, Oregon. The Securities Division alleged that the Respondent offered and/or sold Dine In 2Nite franchises to Washington residents while not registered as a franchise broker in violation of state franchise law. The Division alleged that the Respondent provided prospective franchisees with online financial performance representations that did not contain all the material information about the representations including, but not necessarily limited to, the material basis and assumptions underlying the representations. The Securities Division ordered the Respondent to cease and desist from violations of RCW 19.100.140 and RCW 19.100.170, the franchise broker registration and violations sections of the Franchise Investment Protection Act. The Respondent has a right to request judicial review of this matter.


Dental Data Tech, Inc. and Wesley O. Kronick – S-16-1863-16-CO01 – Consent Order

On June 9, 2016, the Securities Division entered into a Consent Order with Dental Data Tech, Inc. (“Dental Data”) and Wesley O. Kronick (“Kronick”) (collectively, “Respondents”). Dental Data was a Seattle business that was formed to provide electronic recordkeeping and cloud storage for dentists. Kronick was the President of Dental Data. The Securities Division alleged that Kronick offered and sold Dental Data stock to at least one Washington investor for a $30,000 investment. The Securities Division also alleged that the Respondents violated RCW 21.20.010, the anti-fraud provision of the Securities Act of Washington, by misrepresenting or failing to disclose material information when offering and selling the stock. Without admitting or denying the Securities Division’s allegations, Respondents each agreed to cease and desist from violating the Securities Act of Washington. Respondents each waived their right to a hearing and judicial review of this matter.


Ascension Energy Group, Inc. – S-15-1768-16-FO01 - Final Order

On June 6, the Securities Division entered a Final Order to Cease and Desist, Impose Fines, and Recover Costs as to Ascension Energy Group, Inc. (Ascension); Sequoia Energy Project LLLP (Sequoia); Lon E. Stein (Stein); Michael Camacho (Camacho); and Elvis Ronald Mendes a/k/a Ron Mendes (Mendes).

In the Final Order, the Securities Division finds that Ascension, Sequoia, Stein, Camacho, and Mendes violated RCW 21.20.010, the antifraud provision of the Securities Act, by misrepresenting or failing to disclose material information in connection with the sale of partnership interests in Sequoia, an oil and gas project. The Securities Division further finds that Ascension, Sequoia, Stein, Camacho, and Mendes violated RCW 21.20.140, the unregistered securities provision of the Securities Act, by selling unregistered securities, for which no valid claim of exemption existed, to Washington residents. Finally, the Securities Division finds that Ascension, Stein, Camacho, and Mendes violated RCW 21.20.040 by selling securities while unregistered as a securities salesperson or broker-dealer in Washington. The Securities Division orders Ascension, Sequoia, Stein, Camacho, and Mendes to cease and desist from violating the Securities Act of Washington, to pay fines, and to pay investigative costs. Ascension, Sequoia, Stein, Camacho, and Mendes have a right to request judicial review of this matter.


Travis Moegling; Yellowstone Capital, LLC; Bainbridge Views, LLC; Imperium Builder, LLC - S-16-1870-16-TO01 - Summary Order

On June 6, 2016, the Securities Division entered a Summary Order against Travis Moegling; Yellowstone Capital, LLC; Bainbridge Views, LLC; Imperium Builder, LLC (collectively, “Respondents”). The Securities Division alleged that the Respondents violated the anti-fraud provisions of the Securities Act of Washington through the sale of promissory note investments that were secured by deeds of trust. The Summary Order orders the Respondents to cease and desist from violating the Securities Act of Washington, to reimburse the Securities Division for its investigative costs, and to pay fines. The Respondents have a right to request a hearing on the Order.

A Final Order was entered regarding this matter on July 5, 2016.


Neal Inscoe; Alliance of Professionals for Business, Inc. – S-14-1603-16-CO01 – Consent Order

On June 3, 2016 the Securities Division entered into a Consent Order with Respondents Neal Inscoe (“Inscoe”) and Alliance of Professionals for Business, Inc. (“APB”). The Securities Division previously entered a Statement of Charges against Inscoe, APB, and various other respondents on March 7, 2016.

In the Statement of Charges, the Securities Division alleged that Inscoe and APB violated the securities registration, securities salesperson, and antifraud provisions of the Securities Act of Washington in the offer and sale of Life Partners, Inc. life settlements. Without admitting or denying the Securities Division’s allegations, Inscoe and APB agreed to cease and desist from violating the Securities Act of Washington, to pay a fine of $1,750, and to pay investigative costs of $250. Inscoe and APB waived their right to a hearing and judicial review of this matter.


Michael Chapman – S-14-1603-16-CO06 – Consent Order

On June 2, 2016, the Securities Division entered into a Consent Order with Respondent Michael Chapman (“Chapman”). The Securities Division previously entered a Statement of Charges against Chapman and various other respondents on March 7, 2016.

In the Statement of Charges, the Securities Division alleged that Chapman violated the securities registration, securities salesperson, and antifraud provisions of the Securities Act of Washington in the offer and sale of Life Partners, Inc. life settlements. Without admitting or denying the Securities Division’s allegations, Chapman agreed to cease and desist from violating the Securities Act of Washington. Chapman waived his right to a hearing and judicial review of this matter.


Frederick J. Birks, Gryphon Asset Management LLC, Gregory Groeller – S-14-1415-16-FO02 - Final Order

On June 1, 2016, the Securities Division entered a Final Order against Frederick J. Birks (“Birks”), Gryphon Asset Management LLC (“Gryphon”), and Gregory Groeller (“Groeller”). The Securities Division previously entered a Statement of Charges against Birks, Gryphon, Groeller, and other Respondents on April 26, 2016. The Statement of Charges alleged that Birks, Gryphon, and Groeller took part in raising over $19 million for Iverson Genetic Diagnostics, Inc., a genetic testing company, through the sale of unregistered common stock and convertible debt. The Securities Division further alleged that Birks, Gryphon, and Groeller were not registered to solicit such investments and made material misrepresentations or omissions in the offer and sale of the securities. The Final Order orders Birks, Gryphon, and Groeller to cease and desist from violating the Securities Act of Washington. The Final Order orders Birks to pay a fine of $40,000 and Groeller to pay a fine of $10,000. The Final Order orders Birks to pay investigative costs of $1,000 and Groeller to pay investigative costs of $500. Birks, Gryphon, and Groeller have the right to request judicial review of the Final Order


James Lisowsky – S-14-1415-16-FO01 - Final Order

On May 31, 2016, the Securities Division entered a Final Order against James Lisowsky. The Securities Division previously entered a Statement of Charges against Lisowsky and other Respondents on April 26, 2016. The Statement of Charges alleged that Lisowsky took part in raising over $19 million for Iverson Genetic Diagnostics, Inc., a genetic testing company, through the sale of unregistered common stock and convertible debt. The Securities Division further alleged that Lisowsky was not registered to solicit such investments and made material misrepresentations or omissions in the offer and sale of the securities. The Final Order orders Lisowsky to cease and desist from violating the Securities Act of Washington, to pay a fine of $20,000, and to pay investigative costs of $1,000. Lisowsky has the right to request judicial review of the Final Order.


James Billington – S-14-1603-16-CO08 – Consent Order

On May 27, 2016, the Securities Division entered into a Consent Order with Respondent James Billington ("Billington"). The Securities Division previously entered a Statement of Charges against Billington and various other respondents on March 7, 2016.

In the Statement of Charges, the Securities Division alleged that Billington violated the securities registration, securities salesperson, and antifraud provisions of the Securities Act of Washington in the offer and sale of Life Partners, Inc. life settlements. Without admitting or denying the Securities Division’s allegations, Billington agreed to cease and desist from violating the Securities Act of Washington, to pay a fine of $10,000, and to pay investigative costs of $1,000. Billington waived his right to a hearing and judicial review of this matter.


Tomas Delos Santos – S-14-1603-16-FO02 – Final Order

On May 27, 2016 the Securities Division entered a Final Order to Cease and Desist, Impose Fines, and Recover Costs as to Tomas Delos Santos ("Delos Santos"). The Securities Division previously entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, Impose Fines, and to Charge Costs against Life Partners, Inc.; Life Partners Holdings, Inc.; Brian Pardo, R. Scott Peden; David Barr; James Billington; Kim Butler; Gary Cassill; Michael Chapman; Tomas Delos Santos; Neal Inscoe; John Ley; William Meyer; Steven Minnich; Tim Watters; Don Wells; Alliance of Professionals for Business, Inc.; NW Retirement Solutions LLC; NW Safe Retirement LLC; Partners Portfolio Solutions, Inc.; and Strategic Insurance Services, LLC.

In the Final Order, the Securities Division finds that Delos Santos offered and sold unregistered securities, in violation of RCW 21.20.140. The Securities Division further finds that Delos Santos offered and sold securities while unregistered as a securities salesperson, in violation of RCW 21.20.040. The Securities Division further finds that Delos Santos violated RCW 21.20.010 by misrepresenting or failing to disclose material information in connection with the offer and sale of life settlements to Washington residents. The Securities Division orders Delos Santos to cease and desist from violating the Securities Act of Washington, to pay a fine of $460, and to pay investigative costs of $500. Delos Santos has a right to request judicial review of this matter.


Thomas Madden - S-14-1463-15-SC01 - Statement of Charges

On May 23, 2016, 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 Thomas P. Madden.

The Statement of Charges alleges that Thomas P. Madden engaged in fraudulent conduct and acted as an unregistered securities broker-dealer in his sale of stock to Washington residents.

The Securities Division intends to order Thomas P. Madden to cease and desist from violating the Securities Act of Washington and gives notice of its intent to impose a fine and charge costs. Thomas P. Madden has a right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on October 21, 2016.


Steven G. Baldwin - S-15-1790-16-FO01 - Final Order

On May 18, 2016, the Securities Division entered a Final Order against Steven G. Baldwin (“Baldwin”). In the Final Order, the Securities Division finds that Baldwin offered and sold at least $340,000 worth of unregistered stock to at least nine investors. The Securities Division finds that Baldwin misrepresented material information and failed to disclose material information regarding at least two of the investments. The Securities Division orders Baldwin to cease and desist from violating the Securities Act of Washington, to pay a fine of $10,000, and to pay investigative costs of $2,500. Baldwin has a right to request judicial review of this matter.


Ameriprise Financial Services, Inc. - S-14-1575-16-CO02 - Consent Order

On May 18, 2016, the Securities Division entered into a Consent Order with Ameriprise Financial Services, Inc. (“Ameriprise”). The Securities Division previously entered a Statement of Charges against Ameriprise on February 23, 2016. The Statement of Charges alleged that Ameriprise and offered and sold non-traded real estate investment trusts (“REITs”) to customers, including many senior citizens, through unsuitable recommendations and failed to disclose complete information regarding the fees, commissions, and illiquidity of these products. The Securities Division further alleges that Ameriprise failed to adequately supervise Lori Cousineau Weaver, who was formerly a securities salesperson at the firm.

In settling the matter, Ameriprise neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act. The Respondent further agreed to pay a fine of $40,000 and reimburse the Securities Division $15,000 for its costs of investigation. Ameriprise waived its right to a hearing and to judicial review of the matter.


Couch Oil & Gas, Inc., Charles O. Couch – S-14-1417-16-FO01 - Final Order

On May 13, 2016, the Department of Financial Institutions entered a Final Decision & Order Affirming Initial Order on Summary Judgment Motion as to Couch Oil & Gas, Inc. and Charles O. Couch (“Final Order”). The Securities Division had previously entered a Statement of Charges against, among others, Respondents Couch Oil & Gas, Inc. and Charles O. Couch on May 23, 2014. The Statement of Charges alleged that Respondents violated RCW 21.20.010, RCW 21.20.140, and RCW 21.20.040 when they offered and sold $629,375 of unregistered oil and gas investments to Washington residents while failing to disclose material information. On January 13, 2016, Administrative Law Judge Lisa N.W. Dublin issued an Initial Order on Summary Judgment Motion, finding that Respondents Couch Oil & Gas, Inc. and Charles O. Couch violated the Securities Act of Washington as set out in the Statement of Charges. The Final Order affirmed the Initial Order of Summary Judgment Motion, and it ordered Respondents Couch Oil & Gas, Inc. and Charles O. Couch to cease and desist from violating the Securities Act of Washington, ordered Couch Oil & Gas, Inc. to pay a fine of $20,000 and investigative costs of $1,500, and ordered Charles O. Couch to pay a fine of $20,000 and investigative costs of $1,500. Respondents Couch Oil & Gas, Inc. and Charles O. Couch have a right to petition for reconsideration and judicial review of this Final Order.


David Baer – S-16-1853-16-SC01 – Statement of Charges

On May 12, 2016, the Securities Division entered a Statement of Charges against Respondent David Baer of Portland, Oregon. The Securities Division alleges that the Respondent offered and/or sold Dine In 2Nite franchises to Washington residents while not registered as a franchise broker in violation of state franchise law. The Division alleges that the Respondent provided prospective franchisees with online financial performance representations that did not contain all the material information about the representations including, but not necessarily limited to, the material basis and assumptions underlying the representations. The Securities Division intends to order the Respondent to cease and desist from violations of RCW 19.100.140 and RCW 19.100.170, the franchise broker registration and violations sections of the Franchise Investment Protection Act. The Respondent has an opportunity for hearing in this matter.

A Final Order was entered regarding this matter on June 15, 2016.


Dine In 2Nite North America, Inc. and Leo E. Kats - S-16-1853-16-FO01 – Final Order

On May 9, 2016, the Securities Division entered a Final Order against Respondents Dine In 2Nite North America, Inc. and Leo E. Kats, a.k.a. Leonard Katz of San Diego, California. The Securities Division alleged that the Respondents offered and/or sold franchises to Washington residents in violation of state franchise law. The Division alleged that Respondents violated the Franchise Investment Protection Act by offering and selling franchises in Washington while not registered to do so. Respondents provided prospective franchisees with online financial performance representations that did not contain all the material information about the representations including, but not necessarily limited to, the material basis and assumptions underlying the representations. The Securities Division ordered the Respondents to cease and desist from violations of RCW 19.100.020 and RCW 19.100.170, the franchise registration and violations sections of the Franchise Investment Protection Act.


Northwest Crest, LLC; NW Crest Capital, LLC; Scot R. Reynolds – S-14-1528-16-SC01 - Statement of Charges

On May 4, 2016, 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 Northwest Crest, LLC; NW Crest Capital, LLC; and Scot R. Reynolds (“Respondents”). The Statement of Charges alleges that Respondents offered and sold approximately $650,000 of investments to fifteen investors in violation of the registration provisions of the Securities Act of Washington. Further, the Statement of Charges alleges that Respondents violated the anti-fraud provision of the Securities Act of Washington when they failed to disclose material information to the investors, including that investment funds would be used to repay prior investors. The Securities Division intends to order Respondents to cease and desist from violating the Securities Act of Washington, to impose administrative fines, and to charge investigative costs. Respondents each have a right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on March 3, 2017.


Mighty Kicks Franchising, LLC and Luke Vercollone - S-16-1914-16-CO01 - Consent Order

On May 3, 2016, the Securities Division entered into a Consent Order with Respondents Mighty Kicks Franchising, LLC and Luke Vercollone. The Securities Division alleged that the Respondents offered and/or sold a franchise to be located in Washington in violation of state franchise law. The Division alleged that the Respondents violated the Franchise Investment Protection Act by offering and selling franchises in Washington while not registered to do so. Without admitting or denying the Securities Division’s allegations, Respondents agreed to cease and desist from violations of RCW 19.100.020, the franchise registration section of the Franchise Investment Protection Act. The Respondents agreed to reimburse the Securities Division for investigative costs of $1,250 and waived their right to a hearing and judicial review of the matter.


Dental Data Tech, Inc. and Wesley O. Kronick - S-16-1863-16-SC01 – Statement of Charges

On May 3, 2016, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Impose a Fine, and to Charge Costs (“Statement of Charges”) against Dental Data Tech, Inc. (“Dental Data”) and Wesley O. Kronick (“Kronick”) (collectively, “Respondents”). Dental Data was a Seattle business that was formed to provide electronic recordkeeping and cloud storage for dentists. Kronick was the President of Dental Data. In the Statement of Charges, the Securities Division alleges that the Respondents violated RCW 21.20.010, the anti-fraud provision of the Securities Act of Washington, by misrepresenting or failing to disclose material information when offering and selling stock. The Statement of Charges alleges that Kronick offered and sold Dental Data stock to at least one Washington investor for a $30,000 investment. The Securities Division intends to order the Respondents to cease and desist from violating the Securities Act of Washington, to impose a fine, and to charge costs. The Respondents each have a right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on June 9, 2016.


Iverson Genetic Diagnostics, Inc.; Dean Sproles; James Lisowsky; Gregory Groeller; Frederick J. Birks; Dean A. Esposito; Joseph DeVito; Viper Asset Management, LLC; Gryphon Asset Management LLC; DJC Consulting LLC – S-14-1415-15-SC01 - Statement of Charges

On April 26, 2016, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, To Impose Fines and Charge Costs against Iverson Genetic Diagnostics, Inc.; Dean Sproles; James Lisowsky; Gregory Groeller; Frederick J. Birks; Dean A. Esposito; Joseph DeVito; Viper Asset Management, LLC; Gryphon Asset Management LLC; and DJC Consulting (collectively “Respondents”). The Securities Division alleges that Respondents raised over $19 million for Iverson Genetic Diagnostics, Inc., a genetic testing company, through the sale of unregistered common stock and convertible debt. The Securities Division further alleges that Iverson Genetic Diagnsotics, Inc. used unregistered salespersons to solicit the investments and that those salespersons typically had prior administrative orders for violating securities laws and/or criminal records involving theft or fraud. The Securities Division further alleges that Respondents made material misrepresentations or omissions in the offer and sale of the securities. The Securities Division intends to order Respondents to cease and desist from violating the Securities Act of Washington, and gives notice of its intent to impose fines and charges costs. The Respondents have a right to request a hearing on the Statement of Charges.

A Final Order as to Dean Sproles was entered on March 16, 2017.

A Final Order as to Iverson Genetic Diagnostics, Inc was entered on June 28, 2016.

A Final Order was entered regarding this matter on June 17, 2016.

A Final Order as to Frederick J. Birks, Gryphon Asset Management LLC, Gregory Groeller was entered on June 1, 2016.

A Final Order as to James Lisowsky was entered on May 31, 2016.


Brian Pardo – S-14-1603-16-FO01 – Final Order

On April 26, 2016, the Securities Division entered a Final Order to Cease and Desist, Impose Fines, and Recover Costs as to Brian Pardo (“Pardo”). The Securities Division previously entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, Impose Fines, and to Charge Costs against Life Partners, Inc.; Life Partners Holdings, Inc.; Brian Pardo, R. Scott Peden; David Barr; James Billington; Kim Butler; Gary Cassill; Michael Chapman; Tomas Delos Santos; Neal Inscoe; John Ley; William Meyer; Steven Minnich; Tim Watters; Don Wells; Alliance of Professionals for Business, Inc.; NW Retirement Solutions LLC; NW Safe Retirement LLC; Partners Portfolio Solutions, Inc.; and Strategic Insurance Services, LLC.

In the Final Order, the Securities Division finds that Pardo, as CEO of Life Partners, Inc. & Life Partners Holdings, Inc., offered and sold unregistered securities in violation of RCW 21.20.140. The Securities Division further finds that Pardo violated RCW 21.20.010 by misrepresenting or failing to disclose material information in connection with the offer and sale of life settlements to Washington residents. The Securities Division orders Pardo to cease and desist from violating the Securities Act of Washington, to pay a fine of $100,000, and to pay investigative costs of $5,000. Pardo has a right to request judicial review of this matter.


Perma Treat, Inc. and Terry Alan Rennie - S-16-1857-16-SC01 - Statement of Charges

On April 26, 2016, the Securities Division entered a Statement of Charges against Respondents Perma Treat, Inc. and Terry Alan Rennie. The Securities Division alleges that the Respondents offered and/or sold a franchise in the form of a joint venture agreement to a Washington resident in violation of state franchise law. The Division alleges that Respondents violated the Franchise Investment Protection Act by offering and selling franchises in Washington while not registered to do so. Respondents failed to provide a prospective franchisee with a franchise disclosure document with material information about the franchise offering. The Securities Division intends to order the Respondent to cease and desist from violations of RCW 19.100.020 and RCW 19.100.080, the franchise registration and disclosure sections of the Franchise Investment Protection Act. The Respondents each have an opportunity for hearing in this matter.

A Consent Order was entered regarding this matter on June 22, 2016.


Steven G. Baldwin and Zoydan Games, Inc. – S-15-1790-16-SC01 - Statement of Charges

On April 21, 2016, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Impose a Fine, and to Charge Costs (“Statement of Charges”) against Respondents, Steven G. Baldwin and Zoydan Games, Inc. (“Zoydan”). Zoydan is a game company in Spokane, Washington. The Statement of Charges alleges that the Respondents offered and sold at least $340,000 worth of unregistered stock to at least nine investors. The Statement of Charges also alleges that the Respondents misrepresented material information and failed to disclose material information regarding at least two of the investments. The Statement of Charges gives notice of the Securities Division’s intent to impose fines and charge costs. The Respondents each have the right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on May 18, 2016.


Katana Capital, LLC; Robert Kevin Niewijk; and Charles Maximillian Songhurst – S-15-1770-16-CO01 – Consent Order

On April 19, 2016, the Securities Division entered into a Consent Order with Katana Capital, LLC (“Katana Capital”), Robert Kevin Niewijk (“Niewijk”), and Charles Maximillian Songhurst (“Songhurst”) (collectively, “Respondents”). The Securities Division previously entered a Statement of Charges and Notice of Intent to Issue an Order to Cease and Desist, to Deny Future Registrations, to Impose Fines, and to Charge Costs against Respondents on August 28, 2015. In settling the matter, Respondents neither admitted nor denied the Securities Division’s allegations, but have agreed to cease and desist from violating WAC 460-24A-200(1), a books and records violation. Respondents also agreed to pay a fine of $10,000 and costs of $1000. Respondents waived their right to a hearing and judicial review of this matter.


CGI International, Inc. – S-16-1888-16-CO01 – Consent Order

On April 18, 2016, the Securities Division entered into a Consent Order with CGI International, Inc. The Securities Division alleged that CGI International, Inc. violated the registration provisions of the Franchise Investment Protection Act of Washington. Without admitting or denying the Securities Division’s allegations, CGI International, Inc. agreed to cease and desist from violations of the Franchise Investment Protection Act of Washington. CGI International, Inc. further agreed to pay $1,250 in investigative costs and waived its right to a hearing and judicial review of the matter.


Southern Hospitality, LLC; MGI Real Estate Investments, LLC; and Jody L. Marshall – S-14-1583-15-CO01 – Consent Order

On April 8, 2016, the Securities Division entered into a Consent Order with Southern Hospitality, LLC; MGI Real Estate Investments, LLC; and Jody L. Marshall (“Respondents”). The Division had previously entered a Statement of Charges against Respondents on July 28, 2015. The Securities Division alleged that Respondents violated the anti-fraud provision of the Securities Act of Washington when they failed to disclose material facts in the offer and sale of a $100,000 secured promissory note investment to a Washington investor. Without admitting or denying the Division’s allegations, Respondents agreed to cease and desist from violating the Securities Act of Washington. Respondents waived their right to a hearing and judicial review of this matter.


Dine In 2Nite North America, Inc. and Leo E. Katz - S-16-1853-16-SC01 – Statement Of Charges

On March 29, 2016, the Securities Division entered a Statement of Charges against Respondents Dine In 2Nite North America, Inc. and Leo E. Katz, a.k.a. Leonard Katz. The Securities Division alleges that the Respondents offered and/or sold franchises to Washington residents in violation of state franchise law. The Division alleges that Respondents violated the Franchise Investment Protection Act by offering and selling franchises in Washington while not registered to do so. Respondents provided prospective franchisees with online financial performance representations that did not contain all the material information about the representations including, but not necessarily limited to, the material basis and assumptions underlying the representations. The Securities Division intends to order the Respondent to cease and desist from violations of RCW 19.100.020 and RCW 19.100.170, the franchise registration and violations sections of the Franchise Investment Protection Act. The Respondents each have an opportunity for hearing in this matter.

A Final Order was entered regarding this matter on May 9, 2016.


Kirtan Khalsa – S-12-1066-15-CO01 – Consent Order

On March 24, 2016, the Securities Division entered a Consent Order with Kirtan Khalsa (“Respondent”). The Securities Division previously entered a Statement of Charges and Notice of Intent to Issue an Order to Cease and Desist, Impose Fines, and Recover Costs against Respondent and others on April 20, 2015 in connection with the offer and sale of limited liability partnership membership units in an oil and gas company. The Securities Division alleged that Respondent violated RCW 21.20.010, RCW 21.20.040, and RCW 21.20.140 in connection with the offering of unregistered securities. Without admitting or denying the Securities Division’s allegations, Respondent has agreed to cease and desist from violating the Securities Act of Washington. Respondent agreed to pay a fine of $1,000 and costs of $100. Respondent waived its right to a hearing and judicial review of this matter.


Daekyo America, Inc. d.b.a. Eye Level Learning Centers and E.Nopi Learning Centers - S-15-1805-15-CO01 - Consent Order

On March 24, 2016, the Securities Division entered into a Consent Order with Respondent Daekyo America, Inc. d.b.a. Eye Level Learning Centers and E.Nopi Learning Centers. In the Consent Order, the Division alleges that Respondents violated the Franchise Investment Protection Act by offering and selling franchises in Washington while not registered to do so. Without admitting or denying the Securities Division’s allegations, Respondent agreed to cease and desist from violations of RCW 19.100.020, the registration portion of the Franchise Investment Protection Act. Respondent Daekyo America, Inc. d.b.a. Eye Level Learning Centers and E.Nopi Learning Centers also agreed to pay investigative costs of $3,000 and waived its right to a hearing and judicial review of the matter.


Frank H. Black; Southeast Investments, N.C., Inc. - S-11-0597-15-CO02 - Consent Order

On March 14, 2016, the Securities Division entered into a Consent Order with Frank H. Black and Southeast Investments, N.C., Inc. The Securities Division had previously entered a Statement of Charges and Notice of Intent to Issue an Order to Cease and Desist, Deny Future Registrations, Suspend Current Registrations, Impose Fines, and Charge Costs against Damon Vickers, Frank H. Black, and Southeast Investments, N.C., Inc. The Securities Division alleged that Vickers engaged in excessive trading in his customers’ discretionary brokerage accounts. From 2009 through 2012, due to the excessive trading and use of a commission-based compensation structure, Vickers generated approximately $5.3 million dollars in commissions from trading his customer accounts. Certain commissions received by Vickers were unreasonable and constituted a high percentage of the customer’s average portfolio value. Certain commissions were also unreasonable compared to what customers would have been charged with fee-based accounts. Black was the designated supervisor for Damon Vickers, who while subject to Black’s supervision violated the Securities Act of Washington. The Securities Division alleged that Black failed to reasonably supervise Vickers by approving his commission schedule. The Securities Division further alleged that Southeast Investments failed to maintain adequate supervisory policies and procedures regarding the review of discretionary accounts, and as a result Black failed to adequately review Vickers’ accounts for excessive trading. Frank H. Black and Southeast Investments, N.C., Inc. neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act. Frank H. Black and Southeast Investments, N.C., Inc. agreed to pay a $25,000 fine and $5,000 in investigative costs. Frank H. Black and Southeast Investments, N.C., Inc. waived their right to a hearing and to judicial review of the matter.


Damon Vickers - S-11-0597-15-CO01 - Consent Order

On March 9, 2016, the Securities Division entered into a Consent Order with Damon Vickers. The Securities Division had previously entered a Statement of Charges and Notice of Intent to Issue an Order to Cease and Desist, Deny Future Registrations, Suspend Current Registrations, Impose Fines, and Charge Costs against Damon Vickers, Frank H. Black, and Southeast Investments, N.C., Inc. The Securities Division alleged that Vickers engaged in excessive trading in his customers’ discretionary brokerage accounts. From 2009 through 2012, due to the excessive trading and use of a commission-based compensation structure, Vickers generated approximately $5.3 million dollars in commissions from trading his customer accounts. Certain commissions received by Vickers were unreasonable and constituted a high percentage of the customer’s average portfolio value. Certain commissions were also unreasonable compared to what customers would have been charged with fee-based accounts. Damon Vickers neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act of Washington. Damon Vickers agreed to not make application for nor be granted any securities licenses for a period of 5 years and to pay a $15,000 fine and $5,000 in investigative costs. Damon Vickers waived his right to a hearing and to judicial review of the matter.


Shelley Grimes and Surreal Holdings, LLC – S-14-1550-16-CO01 – Consent Order

On March 7, 2016, the Securities Division entered a Consent Order with Shelley Grimes and Surreal Holdings, LLC (collectively, “Respondents”). The Securities Division previously entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Impose Fines, and to Charge Costs (“Statement of Charges”) against Respondents and one other on January 7, 2016. The Securities Division alleged that Respondents violated RCW 21.20.010 and RCW 21.20.140. The Securities Division further alleged that Shelley Grimes violated 21.20.040. Without admitting or denying the Securities Division’s allegations, Respondents have agreed to cease and desist from violating the Securities Act of Washington. Respondents waived their rights to a hearing and judicial review of this matter.


Life Partners, Inc.; Life Partners Holdings, Inc.; Brian Pardo; R. Scott Peden; David Barr; James Billington; Kim Butler; Gary Cassill; Michael Chapman; Tomas Delos Santos; Neal Inscoe; John Ley; William Meyer; Steven Minnich; Tim Watters; Don Wells; Alliance of Professionals for Business, Inc.; NW Retirement Solutions LLC; NW Safe Retirement LLC: Partners Portfolio Solutions, Inc.; Strategic Insurance Services, LLC – S-14-1603-15-SC01 – Statement of Charges

On March 7, 2016, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist against Life Partners, Inc. (LPI); Life Partners Holdings, Inc.; Brian Pardo, R. Scott Peden; David Barr; James Billington (Billington); Kim Butler (Butler); Gary Cassill (Cassill); Michael Chapman (Chapman); Tomas Delos Santos (Delos Santos); Neal Inscoe (Inscoe); John Ley (Ley); William Meyer (Meyer); Steven Minnich (Minnich); Tim Watters (Watters); Don Wells (Wells); Alliance of Professionals for Business, Inc. (APB); NW Retirement Solutions LLC (NW Retirement Solutions); NW Safe Retirement LLC (NW Safe Retirement); Partners Portfolio Solutions, Inc. (PPS); and Strategic Insurance Services, LLC (SIS) (collectively “Respondents”).

In the Statement of Charges, the Securities Division alleges that the Respondents violated the Securities Act of Washington through the offer and sale of approximately $17 million of Life Partners, Inc. life settlements to Washington residents from 2009 to 2014. Specifically, the Statement of Charges alleges that the Respondents violated RCW 21.20.010, the antifraud provision of the Securities Act, by misrepresenting or failing to disclose material information in connection with the sale of LPI life settlements. The Statement of Charges further alleges that the Respondents violated RCW 21.20.140, the unregistered securities provision of the Securities Act by selling unregistered securities. Finally, the Statement of Charges alleges that Billington, Butler, Cassill, Chapman, Delos Santos, Inscoe, Ley, Meyer, Minnich, Watters, Wells, APB, NW Retirement Solutions, NW Safe Retirement, PPS, and SIS violated RCW 21.20.040 by selling LPI life settlements while unregistered as a securities salesperson or broker-dealer in Washington. The Statement of Charges 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 Consent Order as to Steven Minnich was entered on January 3, 2018.

A Consent Order as to David Barr was entered on March 2, 2017.

A Consent Order as to Gary Cassill was entered on February 27, 2017.

A Consent Order as to Scott Peden was entered on February 8, 2017.

A Consent Order as to Donald Wells was entered on August 2, 2016.

A Consent Order as to Life Partners, Inc. & Life Partners Holdings, Inc was entered on July 18, 2016.

A Consent Order as to Tim Watters was entered on July 18, 2016.

A Consent Order as to Kim Butler, Partners Portfolio Solutions, Inc was entered on June 27, 2016.

A Consent Order as to Neal Inscoe; Alliance of Professionals for Business, Inc was entered on June 3, 2016.

A Consent Order as to Michael Chapman was entered on June 2, 2016.

A Consent Order as to James Billington was entered on May 27, 2016.

A Final Order as to Tomas Delos Santos was entered on May 27, 2016.

A Final Order as to Brian Pardo was entered on April 26, 2016.


IOANNIS SPYRIDAKIS – S-14-1475-16-CO01 – Consent Order

On March 7, 2016, the Securities Division entered into a Consent Order S-14-1475-16-CO01 with Ioannis Spyridakis (CRD # 542016). Mr. Spyridakis agreed to the entry of the Consent Order stating that he violated the registration and anti-fraud provisions of the Washington Securities Act. Mr. Spyridakis agreed to cease and desist from further violations; a fine of $25,000; costs of $2,000; and that any applications to act as an investment adviser, investment adviser representative, broker-dealer, or salesperson will be denied for three months from the entry of the Consent Order. The fine is suspended until such time as Mr. Spyridakis applies for Washington registration as an investment adviser, investment adviser representative, broker-dealer, or salesperson. Mr. Spyridakis waived his right to a hearing and judicial review of the matter.


Ascension Energy Group, Inc.; Sequoia Energy Project LLLP; Matthew D. Ehrhardt; Lon E. Stein; Michael Camacho; Kirtan Khalsa; Elvis Ronald Mendes – S-15-1768-16-SC01 – Statement of Charges

On March 2, 2016, 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 Ascension Energy Group, Inc. (Ascension); Sequoia Energy Project LLLP (Sequoia); Matthew Daniel Ehrhardt a/k/a Danny Ehrhardt (Ehrhardt); Lon E. Stein (Stein); Michael Camacho (Camacho); Kirtan Khalsa (Khalsa); and Elvis Ronald Mendes a/k/a Ron Mendes (Mendes).

In the Statement of Charges, the Securities Division alleges that the Respondents violated the Securities Act of Washington through the offer and sale of oil and gas limited partnership interests to Washington residents. Specifically, the Statement of Charges alleges that the Respondents violated RCW 21.20.010, the antifraud provision of the Securities Act, by misrepresenting or failing to disclose material information in connection with the sale of partnership interests in Sequoia. The Statement of Charges further alleges that the Respondents violated RCW 21.20.140, the unregistered securities provision of the Securities Act, by selling unregistered securities, for which no valid claim of exemption existed, to Washington residents. Finally, the Statement of Charges alleges that Ascension, Ehrhardt, Stein, Camacho, Khalsa, and Mendes violated RCW 21.20.040 by selling securities while unregistered as a securities salesperson or broker-dealer in Washington. The Statement of Charges gives notice of the Securities Division’s intent to enter an Order to Cease and Desist, to impose fines, and to charge costs. Respondents have a right to request a hearing on the Statement of Charges.

A Consent Order as to Kirtan Khalsa was entered on August 23, 2016.

A Final Order as to Matthew D. Ehrhardt was entered on August 5, 2016.

A Final Order was entered regarding this matter on June 6, 2016.


Ron Camirand & Associates, L.L.C.; Ron Camirand, Respondents – S-15-1832-16-CO01 – Consent Order

On February 29, 2016, the Securities Division entered Consent Order S-15-1832-16-CO01 wherein Respondent Ron Camirand & Associates, L.L.C. withdrew its pending Washington state investment adviser application and Respondent Ron Camirand withdrew his pending Washington state investment adviser representative registration. The Consent Order resolves the Securities Division’s January 25, 2016, Statement of Charges and Notice of Intent to Deny Applications number S-15-1832-16-SC01 (“Statement of Charges”). The Statement of Charges gave Respondents notice of its intent to deny Respondents’ applications as a result of Respondents being the subject of a final order of the Pennsylvania Securities Administrator barring Respondents from being registered as an investment adviser, investment adviser representative, broker-dealer, or salesperson in Pennsylvania. Respondents waived their right to a hearing on the Washington matter.


Scott B. Wilkerson and WebRotator, Inc. – S-15-1702-15-SC01 – Statement of Charges

On February 29, 2016, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Impose a Fine, and to Charge Costs (“Statement of Charges”) against Scott B. Wilkerson and WebRotator, Inc (“Respondents”). The Statement of Charges alleges that Respondents each violated RCW 21.20.140 by offering and selling more than $2.5 million worth of unregistered stock to more than 100 investors and that Scott B. Wilkerson violated RCW 21.20.040 by offering and selling stock while not being registered as a securities broker-dealer or salesperson. The Statement of Charges also alleges that Respondents both violated RCW 21.20.010, the anti-fraud section of the Securities Act of Washington, by making materially misleading statements or by failing to disclose material information. The Securities Division intends to order Respondents to cease and desist from violating the Securities Act of Washington, to impose a fine, and to charge costs. Respondents each have a right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on August 5, 2016.


Korean Red Ginseng Corp., Inc. – S-16-1849-16-CO01 – Consent Order

On February 23, 2016, the Securities Division entered into a Consent Order with Korean Red Ginseng Corp., Inc. The Securities Division alleged that Korean Red Ginseng Corp., Inc. violated the registration provisions of the Franchise Investment Protection Act of Washington. Without admitting or denying the Securities Division’s allegations, Korean Red Ginseng Corp., Inc. agreed to cease and desist from violations of the Franchise Investment Protection Act of Washington. Korean Red Ginseng Corp., Inc. further agreed to pay $1,250 in investigative costs and waived its right to a hearing and judicial review of the matter.


Lori Cousineau Weaver, Ameriprise Financial Services, Inc. - S-14-1575-15-SC01 – Statement of Charges

On February 23, 2016, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Impose Fines, Suspend Securities Salesperson Registration, and to Charge Costs (“Statement of Charges”) against Lori Cousineau Weaver (“Cousineau Weaver”) and her former firm, Ameriprise Financial Services, Inc. (“Ameriprise”)(collectively, “Respondents”).

The Statement of Charges alleges that the Respondents and offered and sold non-traded real estate investment trusts (“REITs”) to customers, including many senior citizens, through unsuitable recommendations and failed to disclose complete information regarding the fees, commissions, and illiquidity of these products. The Securities Division further alleges that Ameriprise failed to adequately supervise Cousineau Weaver.

The Statement of Charges gives notice of the Securities Division’s intent to suspend Cousineau Weaver’s securities salesperson registration, and to impose fines and charge costs. The Respondents have the right to request a hearing on the Statement of Charges

A Consent Order as to Lori Cousineau Weaver was entered on August 9, 2016.

A Consent Order as to Ameriprise Financial Services was entered on May 18, 2016.


Michael H. Kitson; Kitson Boards, Inc. – S-14-1582-15-CO01 – Consent Order

On February 18, 2016, the Securities Division entered into a Consent Order with Michael H. Kitson and Kitson Boards, Inc. (“Respondents”). The Securities Division had previously entered a Statement of Charges against Respondents on June 8, 2015. The Securities Division alleged that Respondents violated the registration provisions of the Securities Act of Washington when they offered and sold at least $339,000 of unregistered securities to 18 Washington residents. Further, the Division alleged that Respondents violated the anti-fraud provision of the Securities Act of Washington when they failed to disclose material facts in the offer and sale of these securities. Without admitting or denying the Division’s allegations, Respondents agreed to cease and desist from violating the Securities Act of Washington. Respondents waived their right to a hearing and judicial review of this matter.


All Wave Engineering, Inc; Ronald S Bowles; Greg Elseth; Rolly Fuller – S-14-1594-16-CO01 - Consent Order

On February 18, 2016, the Securities Division entered into a Consent Order with All Wave Engineering, Inc., d/b/a All Wave Innovations, Inc.; Gregory T. Elseth; Rolly E. Fuller; and Ronald S. Bowles (“Respondents”). The Securities Division had previously entered a Statement of Charges against Respondents on January 4, 2016. The Securities Division alleged that Respondents violated RCW 21.20.140 and RCW 21.20.040 when they offered and sold $329,000 of unregistered stock to 31 investors. The Division also alleged that Respondents violated RCW 21.20.010, the anti-fraud section of the Securities Act of Washington. Without admitting or denying the Division’s allegations, Respondents agreed to cease and desist from violating the Securities Act of Washington. Respondent All Wave Engineering, Inc. also agreed to pay an administrative fine of $10,000 and investigative costs of $5,000. Respondents waived their right to a hearing and judicial review of this matter.


Joseph Finateri – S-12-1066-16-FO11 – Final Order

On February 5, 2016, the Securities Division entered a Final Order to Cease and Desist, Impose Fines, and Recover Costs against Joseph Finateri (“Finateri”). The Securities Division previously entered a Statement of Charges and Notice of Intent to Issue an Order to Cease and Desist, Impose Fines, and Recover Costs against Finateri and others on April 20, 2015 in connection with the offer and sale of limited liability partnership membership units in oil and gas companies. In the Final Order, the Securities Division finds that Finateri offered and sold unregistered securities, acted as an unregistered broker-dealer or securities salesperson, and violated the anti-fraud provision of the Securities Act of Washington. The Securities Division orders Finateri to cease and desist from violating the Securities Act of Washington, and to pay a fine of $10,000 and costs of $500. Finateri has a right to request judicial review of this matter.


iCare Repair, LLC – S-15-1816-15-CO01 – Consent Order

On January 28, 2016, the Securities Division entered into a Consent Order with iCare Repair, LLC. The Securities Division alleged that iCare Repair, LLC violated the registration and disclosure document provisions of the Franchise Investment Protection Act of Washington. Without admitting or denying the Securities Division’s allegations, iCare Repair, LLC agreed to cease and desist from violations of the Franchise Investment Protection Act of Washington. iCare Repair, LLC further agreed to pay $625 in investigative costs and waived its right to a hearing and judicial review of the matter.


CBMed, LLC; Roland Clarke aka Rory Clarke – S-14-1406-15-CO01 – Consent Order

On January 26, 2015, the Securities Division entered into a Consent Order with CBMed, LLC and Roland Clarke aka Rory Clarke. The Securities Division had previously entered a Statement of Charges alleging that these Respondents violated the Securities Act of Washington by selling LLC membership units and promissory notes without proper registration and disclosures. Without admitting or denying the Security Division’s allegations, CBMed, LLC and Roland Clarke aka Rory Clarke agreed to cease and desist from violating the Securities Act. Roland Clarke aka Rory Clarke also agreed to pay $2,000.00 in fines and $1,000.00 in investigative costs. These Respondents further waived their right to a hearing and judicial review of the matter.


ADV Solutions d/b/a PrimeCash.net - S-14-1599-16-FO01 – Final Order

On January 25, 2016, the Securities Division entered a Final Order against ADV Solutions d/b/a PrimeCash.net. The Securities Division previously entered a Statement of Charges against the Respondent on July 30, 2015, alleging that the Respondent violated the Business Opportunity Fraud Act through the offer and sale of a business opportunity to an elderly Washington resident. The Securities Division orders the Respondent to cease and desist from violating the registration and disclosure document provisions of the Business Opportunity Fraud Act. The Respondent has the right to request judicial review of this matter.


Ron Camirand & Associates, L.L.C.; Ron Camirand, Respondents – S-15-1832-16-SC01 – Statement of Charges

On January 25, 2016, the Securities Division entered Statement of Charges S-15-1832-16-SC01 giving notice of the intent to deny the investment adviser application of Respondent Ron Camirand & Associates, L.L.C. and the investment adviser representative registration of Respondent Ron Camirand as a result of Respondents being the subject of a Consent Agreement and Order by the Pennsylvania Securities Administrator barring Respondents from being registered as an investment adviser, investment adviser representative, broker-dealer, or salesperson in Pennsylvania. Respondents have a right to a hearing on the matter.

A Consent Order was entered regarding this matter on February 29, 2016.


Comp Cost Solutions Cooperative Marketing Company, LLC, Richard Kruckeberg and Barry Thomas – S-13-1268-15-CO01 – Consent Order

On January 19, 2016, the Securities Division entered into a Consent Order with Comp Cost Solutions Cooperative Marketing Company, LLC, Richard Kruckeberg and Barry Thomas. The Securities Division had previously entered a Statement of Charges alleging that these Respondents violated the Securities Act of Washington by selling LLC membership units and promissory notes. Without admitting or denying the Security Division’s allegations, Comp Cost Solutions Cooperative Marketing Company, LLC, Richard Kruckeberg and Barry Thomas agreed to cease and desist from violating the Securities Act and to pay a combined total of $6,000 in fines and $4,000 in investigative costs. These Respondents further waived their right to a hearing and judicial review of the matter.


LPL Financial LLC – S-15-1795-15-CO01 – Consent Order

On January 15, 2016, the Securities Division entered Consent Order S-15-1795-15-CO01 with LPL Financial LLC (“LPL”). The Consent Order represents a settlement negotiated by a multistate task force of state regulators formed by the North American Securities Administrators Association. The Securities Division alleged that LPL had failed to implement an adequate supervisory system relating to the sale of non-traded real estate investment trusts (“REITS”). Without admitting or denying the Securities Division’s allegations, LPL agreed to cease and desist from violating the Washington State Securities Act, to pay a civil penalty of $65,766.07, and to offer to remediate losses on non-traded REITs it had sold to certain Washington investors. LPL waived its right to a hearing and judicial review of the matter.


Troy Van Sickle; Shelley Grimes; and Surreal Holdings, LLC – S-14-1550-15-SC01 – Statement of Charges

On January 7, 2016, 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 Troy Van Sickle (“Van Sickle”); Shelley Grimes (“Grimes”); and Surreal Holdings, LLC (“Surreal Holdings”) (collectively, “Respondents”). The Securities Division alleges that Van Sickle defrauded at least $1.1 million from at least six Washington State residents through the offer and sale of investments in investment contracts and evidence of indebtedness. The Securities Division alleges that Van Sickle targeted these Washington State investors through his purported investment recovery business, Van-Sickle Business Consulting, LLC. One of the Washington State residents that the Securities Division alleges Van Sickle defrauded was Grimes. In addition to the allegation of defrauding Grimes, the Securities Division alleges that Van Sickle convinced Grimes to raise money from other Washington State investors. The Securities Division further alleges that Van Sickle made material omissions and misrepresentations to investors; most notably, Van Sickle failed to disclose to investors his criminal record including that he was currently on probation for fraud and theft. The Securities Division alleges that a vast majority of the $1.1 million that Van Sickle raised is unaccounted for. The Securities Division alleges that Van Sickle, Grimes, and Surreal Holdings violated RCW 21.20.010, the anti-fraud provision of the Securities Act of Washington. The Securities Division also alleges that Van Sickle, Grimes, and Surreal Holdings offered or sold unregistered securities in violation of RCW 21.20.140. The Securities Division alleges that Van Sickle and Grimes violated RCW 21.20.040 by acting as an unregistered broker-dealer and/or securities salesperson. The Statement of Charges gives notice to Respondents of the Securities Division’s intent to enter an order to cease and desist from violating the Securities Act of Washington, to impose fines, and to charge costs. Respondents have a right to request a hearing on the Statement of Charges.

A Consent Order as to Troy Van Sickle was entered on January 25, 2017.

A Consent Order as to Shelley Grimes and Surreal Holdings, LLC was entered on March 7, 2016.


Volodimyr Pigida; Marina Bondarenko – S-14-1482-15-CO01 – Consent Order

On January 7, 2016, the Securities Division entered Consent Order S-14-1482-15-CO01 with Volodimyr Pigida and Marina Bondarenko. The Securities Division had previously entered a Statement of Charges against Pigida, Bondarenko, and their former company Trend Sound Promoter AMG Corp., alleging that the respondents violated the Business Opportunity Fraud Act through their offer and sale of an Internet marketing business opportunity to approximately 6,750 purchasers worldwide. The Securities Division subsequently issued a Final Order as to Trend Sound Promoter AMG, Corp. Without admitting or denying the Securities Division’s allegations, Pigida and Bondarenko agree to cease and desist from violating the Business Opportunity Fraud Act and to pay $8,000 in investigative costs. Pigida and Bondarenko waived their right to a hearing and judicial review of the matter.


John Charles Hanson – S-14-1592-15-CO01 - Consent Order

On January 4, 2016, the Securities Division entered a Consent Order with Respondent John Charles Hanson. The Securities Division had previously entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, To Deny Future Registrations, To Impose Fines, and To Charge Costs ("Statement of Charges") against Hanson alleging that he sold fictitious investments and made unauthorized withdrawals and policy loans from the accounts of his advisory clients, totaling at least $2.4 million. Without admitting or denying the Security Division’s allegations, Hanson agreed to cease and desist from violating the Securities Act, to never apply to register as a broker-dealer, securities salesperson, investment adviser, or investment adviser representative with the Securities Division, to pay a fine of $120,000 and costs in the amount of $5,000. The fines and costs will be waived if Hanson makes full restitution. Hanson waived his right to a hearing and judicial review of the matter.


Michael Pucci, Ashley Zdeb and Dystopia Rising, LLC - S-15-1714-15-CO01 - Consent Order

On January 12, 2016, the Securities Division entered into a Consent Order with Respondents Michael Pucci, Ashley Zdeb and Dystopia Rising, LLC. The Securities Division had previously entered a Statement of Charges against the Respondents on December 17, 2015. The Division alleged that Respondents violated the Franchise Investment Protection Act by offering and selling franchises in Washington while not registered to do so and failing to provide prospective franchisees with a Franchise Disclosure Document. Without admitting or denying the Securities Division’s allegations, Respondents agreed to cease and desist from violations of RCW 19.100.020 and RCW 19.100.080, the registration and disclosure document portions of the Franchise Investment Protection Act. Respondents Michael Pucci, Ashley Zdeb and Dystopia Rising, LLC also agreed to pay investigative costs of $12,000 and waived their right to a hearing and judicial review of the matter.


Eulysses B. Lewis – S-14-1496-15-CO02 - Consent Order

On January 4, 2016, The Securities Division entered into a Consent Order with Eulysses B. Lewis (“Lewis”). The Division had entered a Statement of Charges against Lewis and TreeFree Biomass Solutions, Inc. in which the Division alleged that Lewis violated the Securities Act of Washington’s (the “Act”) securities registration, securities salesperson registration, and anti-fraud provisions by offering and selling TreeFree stock. Without admitting or denying the Division’s allegations, Lewis agreed to cease and desist from violating the Act, to pay a $15,000 fine, and to reimburse the Division $5,000 in investigative costs. Lewis waived his right to an adjudicative hearing and judicial review of this matter.


TreeFree Biomass Solutions, Inc – S-14-1496-15-CO01 - Consent Order

On January 4, 2016, The Securities Division entered into a Consent Order with TreeFree Biomass Solutions, Inc. (“TreeFree”). The Division had entered a Statement of Charges against TreeFree and Eulysses B. Lewis in which the Division alleged that TreeFree violated the Securities Act of Washington’s (the “Act”) securities registration and anti-fraud provisions by offering and selling its stock. Without admitting or denying the Division’s allegations, TreeFree agreed to cease and desist from violating the Act, to pay a $15,000 fine, and to reimburse the Division $5,000 in investigative costs. TreeFree waived its right to an adjudicative hearing and judicial review of this matter.


All Wave Engineering, Inc.; Ronald S. Bowles; Greg T. Elseth; Rolly Fuller – S-14-1594-15-SC01 - Statement of Charges

On January 4, 2016, 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 All Wave Engineering, Inc., d/b/a All Wave Innovations, Inc.; Gregory T. Elseth; Rolly E. Fuller; and Ronald S. Bowles (“Respondents). The Statement of Charges alleges that Respondents violated RCW 21.20.140 and RCW 21.20.040 when they offered and sold $329,000 of unregistered stock to 31 investors. The Statement of Charges also alleges that Respondents violated RCW 21.20.010, the anti-fraud section 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, to impose administrative fines, and to charge costs. Respondents each have a right to request a hearing on the Statement of Charges.

A Consent Order regarding this matter was entered on February 18, 2016.