2018 Division of Securities Enforcement Actions

Orders From Other Years

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Neighborhood Networks Publishing, Inc. - S-18-2456-18-SC01 - Statement of Charges

On November 5, 2018, the Securities Division entered into a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist (“Statement of Charges”) against Neighborhood Networks Publishing, Inc. (“Respondent”). In the Statement of Charges, the Securities Division alleged that Respondent violated the Franchise Investment Protection Act (“FIPA”) by offering and selling franchises to at least 30 Washington residents while not registered to do so and by failing to provide them with a franchise disclosure document. The Securities Division also alleged that Respondent made misleading financial performance representations while offering and selling the franchises. The Statement of Charges gives notice of the Securities Division’s intent to order Respondent to cease and desist from further violating FIPA. Respondent has the right to request a hearing on the Statement of Charges.


Gregory D. Mrachek, - S-17-2185-18-CO01 - Consent Order

On October 23, 2018, the Securities Division entered into a Consent Order with Gregory Mrachek. The Securities Division had previously entered a Statement of Charges and Notice of Intent to Issue an Order to Cease and Desist, Impose Fines, and Charge Costs against InfoScape Corporation and Gregory D. Mrachek. The Statement of Charges alleged that the Respondents raised over $650,000 from selling a fourth series of convertible promissory notes, including to at least 12 Washington residents. The Statement of Charges further alleged that Respondent Mrachek acted as an unregistered broker-dealer and/or securities salesperson, and that the offer and sale of securities by the Respondents violated the anti-fraud provision of the Securities Act of Washington. Respondent Mrachek neither admitted nor denied the allegations, but agreed to cease and desist from violating the Securities Act of Washington. Respondent Mrachek agreed to pay a $2,000 fine and $1,000 in investigative costs. Respondent Mrachek waived his right to a hearing and to judicial review of the matter.


Kerry L. SimsHauser, Aardvark Organics Inc., Aqua Vita, LLC, Jerry A. Scholten, ICON Organics Inc. – S-17-2224-18-SC01 - Statement of Charges

On October 2nd, 2018, 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 against Kerry L. Simshauser; Aardvark Organics Inc.; Aqua Vita, LLC; Jerry A. Scholten; and ICON Organics Inc. (collectively “Respondents”). The Statement of Charges alleges that from 2009 to 2014, the Respondents offered and sold a total of more than $1.1 million of investments to six Washington investors. The Respondents represented that the investors would receive large returns from the sale of organic products and agricultural technologies. The Statement of Charges alleges that SimsHauser was an unregistered securities salesperson who sold unregistered stock. The Statement of Charges further alleges that each of the Respondents violated RCW 21.20.010, the anti-fraud provision of the Securities Act of Washington. The Securities Division gave notice of its intent to impose fines and charge costs. The Respondents each have the right to request a hearing on the Statement of Charges.


Capital Energy Group LLC; Frank August; Cap E Oil Fund 1, LLP; Cap E Oil Fund II, LLC; Cap E Oil Fund III, LLC; and Cap E Oil Fund V, LLC – S-16-2045-17-SC01 - Statement of Charges

On October 2nd, 2018, 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 Capital Energy Group LLC; Frank August; Cap E Oil Fund 1, LLP; Cap E Oil Fund II, LLC; Cap E Oil Fund III, LLC; and Cap E Oil Fund V, LLC (collectively, “Respondents”). The Statement of Charges alleges that the Respondents violated the registration and anti-fraud provisions of the Securities Act of Washington when they offered and sold more than $400,000 worth of oil and gas investments to three Washington investors. The Securities Division intends to order the Respondents to cease and desist from violating the Securities Act of Washington and gives notice of its intent to impose a fine and to charge costs. The Respondents each have a right to request a hearing on the Statement of Charges.


Grow Healthy Vending, LLC f/k/a Grow Franchise Group LLC; Chris Wyland - S-17-2214-18-FO01 - Final Order

On October 2nd, 2018, the Securities Division entered a Final Order against Grow Healthy Vending, LLC f/k/a Grow Franchise Group LLC and Chris Wyland (collectively, “Respondents”). The Final Order found that the Respondents violated the Washington Business Opportunity Fraud Act (the “Act”) by offering and selling business opportunities in the form of vending machines and location procurement services to at least seven Washington residents. The Final Order also found that Respondents failed to register their business opportunities with the Division, failed to provide the Washington purchasers with the required disclosure document, and failed to provide the purchasers with material information. The Final Order found that Respondents’ actions violated the registration, anti-fraud, disclosure document, and contract provisions of the Act, and ordered them to cease and desist from violating these provisions. The Respondents each have the right to petition the superior court for judicial review of the order.


William Derrington - S-17-2276-18-SC01 - Statement of Charges

On September 28, 2018, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Revoke Registration, to Deny Future Registrations, to Impose a Fine, and to Charge Costs (“Statement of Charges”) against Respondent William Derrington (“Derrington”) CRD #1325480.

In the Statement of Charges, the Securities Division alleges that Derrington violated the Securities Act of Washington by engaging in dishonest and unethical business practices. Specifically, the Securities Division alleges that Derrington borrowed money from a client, purportedly on behalf of his daughter, and failed to disclose the loan to his firm. The Statement of Charges gives notice of the Securities Division’s intent to enter an order to impose fines of $5,230, to charge costs of $1,000, to revoke Derrington’s securities salesperson registration in Washington, and to deny any of Derrington’s future investment adviser, investment adviser representative, broker-dealer, or securities salesperson applications for registration. Derrington has a right to request a hearing on the Statement of Charges.


Stephen Coupe – S-18-2490-18-CO01 - Statement of Charges

On September 28, 2018, the Securities Division entered into a Consent Order S-18-2490-18-CO01 with Stephen Coupe (CRD 2061979) (“Consent Order”). The Consent Order states Coupe was registered as a securities salesperson and an investment adviser representative when he exercised unauthorized discretion in brokerage customers’ accounts. The Consent Order states that these acts violated RCW 21.20.110(1)(g), WAC 460-22B-090(8) and WAC 460-22B-090(9). The Consent Order includes a $5,000 fine, costs of $1,000, and conditions any future registration requests by Respondent upon a sponsoring firm providing an acceptable plan of supervision. Respondent waived his right to request judicial review of the matter.


Somatika Incorporated and William D. Enersen - S-17-2359-18-CO01 - Consent Order

On 09/13/2018, the Securities Division entered a Consent Order with Somatika Incorporated ("Somatika") and William D. Enersen ("Enersen"). The Securities Division had previously entered a Statement of Charges against Somatika and Enersen. In the Statement of Charges, the Securities Division alleged that from 2014 to 2016, Somatika, Enersen, and Laura E. Davidson ("Davidson") had sold approximately $470,000 worth of unregistered Somatika stock to approximately 20 investors, including at least 3 Washington investors. The Statement of Charges alleged that Enersen and Davidson were both unregistered broker-dealers and/or securities salespersons and that Somatika, Enersen, and Davidson had violated the anti-fraud provision of the Securities Act of Washington.

Without admitting or denying the Securities Division's allegations, Somatika and Enersen agreed to cease and desist from violating the Securities Act. Enersen paid $1,000 in fines and $500 of investigative costs. Somatika and Enersen waived their right to a hearing and to judicial review of the matter.


Fitness Concepts Inc., The Camp Bootcamp Inc., Saman Bakhtiar - S-18-2491-18-CO01 - Consent Order

On September 6, 2019, the Securities Division entered into a Consent Order with Fitness Concepts Inc., The Camp Bootcamp Inc., and Saman Bakhtiar (“Respondents”). In the Consent Order, the Securities Division alleged that Respondents violated the Franchise Investment Protection Act (“FIPA”) by offering and selling franchises related to fitness centers in Washington while not being registered for such activities. The Securities Division further alleged that the Respondents failed to provide the purchaser with a franchise disclosure document. Without admitting or denying the allegations, Respondents agreed to cease and desist from violating FIPA and pay costs of $500. The Respondents also each waived their right to a hearing and judicial review of this matter.


Lightfleet Corporation - S-16-2029-17-CO01 - Consent Order

On September 4, 2018, the Securities Division entered into a Consent Order with Lightfleet Corporation.

The Securities Division alleges that Lightfleet Corporation violated a registration provision of the Securities Act of Washington in connection with some of the company.


Jack T. Jarrell and OAG Wealth Management, LLC, - S-16-2066-18-CO01 - Consent Order

On August 31, 2018, the Securities Division entered into a Consent Order with Respondents Jack T. Jarrell and OAG Wealth Management, LLC. In the Consent Order, the Securities Division alleged that Jack T. Jarrell and OAG Wealth Management, LLC violated the Securities Act by offering and selling unregistered securities in the form of Providence Financial, Inc. and Providence Fixed Income Fund, LLC promissory notes, acted as a broker dealer or securities salesperson while not registered to do so, and omitted to state material facts in connection with the offer and sale of securities. Without admitting or denying the Securities Division’s allegations, Respondents agreed to cease and desist from violations of RCW 21.20.140, the registration of securities provision, RCW 21.20.040, the salesperson and broker-dealer registration provision, and RCW 21.20.010 the anti-fraud provision of the Securities Act. Respondents are permanently barred from registering as a broker-dealer and investment adviser. Respondent Jack Jarrell is permanently barred from registering as securities salesperson and investment adviser representative. Respondents waived their right to a hearing and judicial review of the matter.


Kory Penland Keath – S-18-2407-18-CO01 - Consent Order

On August 28, 2018, the Securities Division entered a Consent Order with Respondent Kory Penland Keath (“Keath”), CRD #1242675. The Securities Division had previously entered a Statement of Charges against Keath relating to an order by the Financial Industry Regulatory Authority which barred Keath from association with any FINRA member. In the Consent Order, Keath neither admitted nor denied the Securities Division’s Findings of Fact and Conclusions of Law, but agreed to cease and desist from violating WAC 460-22B-090, and to pay a fine of $250 and investigative costs of $200. Keath also agreed not to apply for investment adviser, investment adviser representative, broker-dealer, or securities salesperson registration in Washington for two years from the date of entry of the Consent Order. Keath waived her right to a hearing and to judicial review of this matter.


Jeffrey A. Mascio - S-17-2194-18-SC01 - Statement of Charges

On August 27, 2018, the Securities Division entered a Statement of Charges and Notice of Intent to Issue an Order to Cease and Desist, Deny Future Registrations, Impose Fines, and Charge Costs against Jeffrey A. Mascio. The Statement of Charges alleges that the Respondent, while providing investment advisory services to two Washington residents, made unsuitable trades for the customers which resulted in a loss of over $750,000 dollars. The Statement of Charges further alleges that Mascio executed unauthorized trades for the residents’ accounts because he continued to make high risk securities trades in their accounts after they requested that he stop. The Statement of Charges alleges that the Respondent violated the suitability provision of the Securities Act of Washington and engaged in dishonest and unethical practices. The Securities Division ordered the Respondent to cease and desist from violating the Securities Act of Washington, and gave notice of its intent to deny any future registration applications, impose fines and charge costs. The Respondent has a right to request a hearing on the Statement of Charges.


Somatika Incorporated, William D. Enersen, Laura E. Davidson - S-17-2359-18-SC01 - Statement of Charges

On August 24, 2018, 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 Somatika Incorporated, William D. Enersen, and Laura E. Davidson (collectively “Respondents”). Somatika’s primary business purpose was to sell formulas for skin care products that would be manufactured with inert stem cells. The Statement of Charges alleges that from 2014 to 2016, the Respondents sold approximately $470,000 worth of unregistered Somatika stock to approximately 20 investors, including at least 3 Washington investors. The Statement of Charges alleges that Enersen and Davidson were both unregistered broker-dealers and/or securities salespersons and that the Respondents violated the anti-fraud provision of the Securities Act of Washington. The Securities Division gave notice of its intent to impose fines and charge costs. Respondents each have the right to request a hearing on the Statement of charges.

A Consent Order as to William D. Enersen was entered on September 13, 2018.


Advisory Services Group, Inc, Julia Williams - S-16-2106-18-FO01 - Final Order

On August 8, 2018, the Department of Financial Institutions entered a Final Decision & Order (“Order”) against Respondents, Advisory Services Group, Inc. and Julia Williams (“Respondents”). The Order found that the Respondents offered and sold more than $150,000 of investments to three investors. The Order found that the Respondents violated RCW 21.20.010, the anti-fraud section of the Securities Act of Washington. The Order imposed a fine of $20,000 and costs of $2,500. The Respondents each have the right to petition the superior court for judicial review of the order.


Pacific Watercraft Group, Inc - S-16-1868-18-CO03 - Consent Order

On August 6, 2018, the Securities Division entered into Consent Orders with Respondents Pacific Watercraft Group, Inc., Scott E. Anderson, and Robin Lynn Sells (“Respondents”). The Securities Division had previously entered a Statement of Charges against Respondents alleging that they offered and sold $90,000 of shares in Pacific Watercraft Group, Inc. to three investors in violation of the Securities Act of Washington (“the Act”). Without admitting or denying the allegations, Pacific Watercraft Group, Inc. agreed to cease and desist from violating a registration provision of the Act, to pay a fine of $2,500, and to pay investigative costs of $3,000; Scott E. Anderson agreed to cease and desist from violating registration provisions of the Act, and to pay a fine of $2,500; and Robin Lynn Sells agreed to cease and desist from violating registration and anti-fraud provisions of the Act, and to pay a fine of $5,000. Respondents each waived their right to a hearing and judicial review of this matter.


Robyn Sells - S-16-1868-18-CO01 - Consent Order

On August 6, 2018, the Securities Division entered into Consent Orders with Respondents Pacific Watercraft Group, Inc., Scott E. Anderson, and Robin Lynn Sells (“Respondents”). The Securities Division had previously entered a Statement of Charges against Respondents alleging that they offered and sold $90,000 of shares in Pacific Watercraft Group, Inc. to three investors in violation of the Securities Act of Washington (“the Act”). Without admitting or denying the allegations, Pacific Watercraft Group, Inc. agreed to cease and desist from violating a registration provision of the Act, to pay a fine of $2,500, and to pay investigative costs of $3,000; Scott E. Anderson agreed to cease and desist from violating registration provisions of the Act, and to pay a fine of $2,500; and Robin Lynn Sells agreed to cease and desist from violating registration and anti-fraud provisions of the Act, and to pay a fine of $5,000. Respondents each waived their right to a hearing and judicial review of this matter.


Scott Anderson - S-16-1868-18-CO02 - Consent Order

On August 6, 2018, the Securities Division entered into Consent Orders with Respondents Pacific Watercraft Group, Inc., Scott E. Anderson, and Robin Lynn Sells (“Respondents”). The Securities Division had previously entered a Statement of Charges against Respondents alleging that they offered and sold $90,000 of shares in Pacific Watercraft Group, Inc. to three investors in violation of the Securities Act of Washington (“the Act”). Without admitting or denying the allegations, Pacific Watercraft Group, Inc. agreed to cease and desist from violating a registration provision of the Act, to pay a fine of $2,500, and to pay investigative costs of $3,000; Scott E. Anderson agreed to cease and desist from violating registration provisions of the Act, and to pay a fine of $2,500; and Robin Lynn Sells agreed to cease and desist from violating registration and anti-fraud provisions of the Act, and to pay a fine of $5,000. Respondents each waived their right to a hearing and judicial review of this matter.


Gordon Bolster Advisors, LLC and Gordon Bolster - S-17-2343-18-SC01 - Statement of Charges

On August 3, 2018, the Securities Division entered Statement of Charges and Notice of Intent to Enter an Order to Cease and Desist, Deny Future Registrations, Impose Fines, and Charge Costs against Gordon Bolster Advisors, LLC (CRD 167875) and Gordon Bolster (CRD 4175826) (“Statement of Charges”). Gordon Bolster Advisors, LLC (“GBA”) is registered as an investment adviser and Bolster is its managing member and is registered as an investment adviser representative. The Statement of Charges alleges that Respondents failed to meet its minimum financial requirement, failed to renew its registration, and failed to inform the Securities Division that it entered into an Agreed Order with another securities regulator. The Statement of Charges further alleges that Gordon Bolster sold an unregistered security. The Statement of Charges gives notice of an intent to enter an order to cease and desist, revoke future registrations, and collect fines and costs. Respondents have a right to request a hearing on the Statement of Charges.


Shaun Brog; Ryan Brog; Kenyon Capital Investment Holdings LLC – S-17-2137-18-SC01 - Statement of Charges

On August 3, 2018, the Securities Division (“the Division”) 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 Respondents Shaun Brog (CRD #5000205), Ryan Brog (CRD #5798126), and Kenyon Capital Investment Holdings LLC (“Kenyon Capital”) In the Statement of Charges, the Securities Division alleges that Shaun Brog, Ryan Brog, and Kenyon Capital (collectively “the Respondents”) violated the Securities Act of Washington and accompanying regulations in the course of the offer and sale of interests in Kenyon Capital, and subsequently in the administration of Kenyon Capital. Specifically, the Division alleges (a) that the Respondents misrepresented or failed to disclose material information in connection with the offer and sale of interests in Kenyon Capital; (b) that the Respondents engaged in an act, practice, or course of business which operated as a fraud on their investors by failing to comply with Washington’s custody requirements; (c) that the Respondents entered into contracts with investors which illegally provided for performance-based fees; (d) that Shaun and Ryan Brog acted as unregistered securities salespersons when selling interests in Kenyon Capital and unregistered investment advisers when managing Kenyon Capital; and (e) that the Respondents offered and sold unregistered securities in the form of LLC interests in Kenyon Capital. The Statement of Charges gives notice of the Securities Division’s intent to enter an order to cease and desist from violations of the Securities Act of Washington, to impose fines of $200,000, to charge costs of $20,000, and to deny any of the Respondents’ future investment adviser, investment adviser representative, broker-dealer, or securities salesperson applications for registration. The Respondents have a right to request a hearing on the Statement of Charges.


Moore Wealth Management, L.L.C. - S-16-2092-17-CO01 - Consent Order

On August 1, 2018, the Securities Division entered a Consent Order S-16-2092-17-CO01 with Moore Wealth Management, L.L.C. (“Consent Order”). Moore Wealth Management (CRD # 143378) is registered as an investment adviser and Karl Moore (CRD # 274907) is its principal. The Consent Order states that Respondent failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Securities Act, the investment advisory rules, and the federal securities laws. The Consent Order further states that Respondent employed an unregistered investment adviser representative. The Consent Order further states that these acts violated RCW 21.20.040 and WAC 460-24A-120. The Consent Order includes a $5,000 fine and costs of $1,500. Respondent waived its right to request judicial review of the matter.


Timothy Dion Wetzel; Wetzel Oil Inc.; Wetzel Energy Technology Company Inc.; and Better Fuel North West, A WETCO Company, Inc. - S-14-1479-18-FO01 - Final Order

On August 1, 2018, the Director of the Washington Department of Financial Institutions entered a Final Order against Timothy Dion Wetzel (“Wetzel”); Wetzel Oil Inc. (“WOI”); Wetzel Energy Technology Company Inc. (“WETCO”); and Better Fuel North West, A WETCO Company, Inc. (“BFNW”) (collectively, “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. It also found that Wetzel violated RCW 21.20.040 by selling securities while unregistered as a securities salesperson or broker-dealer in Washington. It further found that Wetzel and WETCO violated RCW 19.110.050, RCW 19.110.070, and RCW 19.110.120, the registration, disclosure, and anti-fraud sections, respectively, of the Business Opportunity Fraud Act of Washington. The Final Order ordered Respondents to cease and desist from any further violations of these provisions of the Securities Act and Business Opportunity Fraud Act. The Final Order also ordered Respondents to pay the following fines and costs: (1) Wetzel and WETCO are jointly and severally liable for a fine of $140,000 for violating the Securities Act in connection with the offer and sale of WETCO stock and promissory notes, and for $20,000 in investigative costs; (2) Wetzel and BFNW are jointly and severally liable for a fine of $80,000 in connection with the offer and sale of BFNW stock, and for $10,000 in investigative costs; and (3) Wetzel is liable for an additional fine of $80,000 for violating the Securities Act in connection with the offer and sale of WOI stock, and for $20,000 in investigative costs. The Respondents have the right to petition the superior court for judicial review of the Final Order.


Mitchell R. Johnson – S-17-2327-18-CO01 - Consent Order

On July 24, 2018, the Securities Division entered into a Consent Order with Respondent Mitchell R. Johnson.

The Securities Division had previously entered a Statement of Charges against Mitchell R. Johnson, which alleges that Mitchell R. Johnson submitted false Form U4 filings with the Securities Division by failing to document the full scope of his work with CLA USA as well as a past regulatory action as a result of his work with CLA USA. The Statement of Charges further alleged that Mitchell R. Johnson failed to file an updated or amended Form U4 to document his ongoing work with CLA USA.

Without admitting or denying the Securities Division’s allegations, Mitchell R. Johnson agreed to cease and desist from violating the Securities Act of Washington, pay $1,500 in investigative costs, and pay $1,500 in fines. Mitchell R. Johnson further agreed to not apply to register as a securities broker-dealer, securities salesperson, investment adviser, or investment adviser representative in Washington. Mitchell R. Johnson waived his right to a hearing and judicial review of this matter.


Randy Galten & Anna Galten d/b/a Eat This! - S-17-2300-18-FO01 - Final Order

On July 23, 2018, the Securities Division issued a Final Order against Randy and Anna Galten, who does business as Eat This! On June 19, 2018, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist (the “Statement of Charges”) against Eat This! The Statement of Charges alleged that Eat This! offered equipment, supplies, and marketing support that would enable purchasers to start a business selling Italian style frozen desserts. The Statement of Charges alleged that, in doing so, Eat This! violated the registration and anti-fraud sections of Washington’s Business Opportunity Fraud Act (the “Act”). Eat This! did not make a timely request for an administrative hearing on the Statement of Charges. The Final Order orders Eat This! to cease and desist from violating the Act. Eat This! may request judicial review of the Final Order.


Grow Healthy Vending, LLC f/k/a Grow Franchise Group LLC; Chris Wyland - S-17-2214-18-SC01 - Statement of Charges

On July 5, 2018, the Securities Division entered a Statement of Charges against Grow Healthy Vending, LLC f/k/a Grow Franchise Group LLC and Chris Wyland (collectively, “Respondents”). In the Statement of Charges, the Securities Division alleged that Respondents violated the Washington Business Opportunity Fraud Act (the “Act”) by offering and selling business opportunities in the form of vending machines and location procurement services to at least seven Washington residents. The Securities Division further alleged that Respondents failed to register their business opportunities with the Division, failed to provide the Washington purchasers with the required disclosure document, and failed to provide the purchasers with material information. The Securities Division alleged that Respondents’ actions violated the registration and anti-fraud provisions of the Act. The Statement of Charges gives notice of the Securities Division’s intent to order Respondents to cease and desist from violating the Act. Respondents have the right to request a hearing on the Statement of Charges


FBA Wealth Management, LLC - S-18-2487-18-SC01 - Statement of Charges

On June 27, 2018, the Securities Division entered Statement of Charges and Notice of Intent to Revoke Registrations, Impose a Fine, and Charge Costs S-18-2487-18-SC01 against FBA Wealth Management (CRD 146390) and Adi Benyishay (CRD 2183586) (“Statement of Charges”). FBA Wealth Management (“FBA”) is registered as an investment adviser and Benyishay, FBA’s president, is registered as an investment adviser representative. The Statement of Charges alleges that Respondents violated the financial reporting requirement of the investment advisory rules by failing to file a timely 2016 year-end balance sheet and failing to file a 2017 year-end balance sheet. The Statement of Charges gives notice of an intent to revoke Respondents’ registrations and collect fines and costs. Respondents have a right to request a hearing on the Statement of Charges.


Fan Kam Yip – S-17-2242-18-CO01 - Consent Order

On June 25, 2018, the Securities Division entered into a Consent Order with Respondent Fan Kam Yip (CRD#4775948). The Securities Division alleged that, between April and November 2013, Respondent engaged in dishonest or unethical business practices by selling away, concealing from his firm that he was selling away, and failing to disclose an outside business activity to his firm. Without admitting or denying the allegations, Respondent agreed to not apply for registration as a securities salesperson or investment adviser representative for six months from the date of the Consent Order, to pay a fine of $1,000, and to pay investigative costs of $500. Respondent waived his right to a hearing and judicial review of this matter.


Lawson Financial Corporation and Robert Warren Lawson - S-17-2305-18-CO01 - Consent Order

On June 20, 2018, the Securities Division entered into a Consent Order with Lawson Financial Corporation (“LFC”) and Robert Warren Lawson (“Lawson”). The Securities Division previously entered a Statement of Charges and Notice of Intent to Enter Order to Revoke Registration, and Deny Future Registrations (“Statement of Charges”) against LFC and Lawson on November 9, 2017. The Securities Division alleged in the Statement of Charges that the Financial Industry Regulatory Authority (“FINRA”) expelled LFC and Lawson from FINRA membership for committing securities fraud when they sold millions of dollars of municipal revenue bonds to LFC customers. The Statement of Charges further alleged that the Securities and Exchange Commission (“SEC”) censured LFC and barred Lawson from associations with any broker, dealer, and investment adviser for failing to conduct reasonable due diligence when underwriting bond offerings. Without admitting or denying the Securities Division’s allegations, LFC and Lawson have agreed that any broker-dealer, securities salesperson, investment adviser, or investment adviser representative registration applications LFC or Lawson may file in the future will be denied. LFC and Lawson waived their rights to a hearing and judicial review of this matter.


Randy Galten and Anna Galten d/b/a Eat This! - S-17-2300-18-SC01 - Statement of Charges

On June 19, 2018 the Securities Division entered a Statement of Charges against Randy and Anna Galten, an Idaho couple doing business as Eat This! The Statement of Charges alleges that the Galtens offered equipment, supplies, and marketing support that would enable purchasers to start a business selling Italian style frozen desserts. The Statement of Charges alleges that, in doing so, the Galtens violated Washington’s Business Opportunity Fraud Act (the “Act”). The Statement of Charges gives notice of the Securities Division’s intent to order the Galtens to cease and desist from violating the Act. The Galtens may request an administrative hearing on the Statement of Charges.

A Final Order was entered regarding this matter on July 23, 2018.


Kwench Juice Franchising Inc., - S-18-2418-18-FO01 - Final Order

On June 14, 2018, the Securities Division issued an Entry of Findings of Fact and Conclusions of Law and Final Order to Cease and Desist (“Final Order”) against Kwench Juice Franchising Inc. (“Kwench Juice”). The Securities Division previously entered a Statement of Charges against the Respondent on May 1, 2018. Kwench Juice offered franchises in Washington State without being registered. The Securities Division orders Kwench Juice to cease and desist from violating RCW 19.100.020, the registration provision of the Franchise Investment Protection Act of Washington. Kwench Juice has a right to request judicial review of the matter.


Investment Hiker, LLC – S-18-2435-18-CO01 – Consent Order

On June 12, 2018, the Securities Division entered Consent Order S-18-2435-18-CO01 with Investment Hiker, LLC (“Consent Order”). In the Consent Order Investment Hiker (IARD 160065) agreed to cease and desist from violating the Washington Securities Act by acting as an unregistered investment adviser. Respondent also agreed to pay a fine. Respondent waived its right to a hearing and judicial review of the matter.


InfoScape Corporation; Gregory D. Mrachek, - S-17-2185-18-SC01 - Statement of Charges

On June 6, 2018, 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 InfoScape Corporation and Gregory D. Mrachek (collectively “Respondents”). The Statement of Charges alleges that the Respondents raised over $650,000 from selling a fourth series of convertible promissory notes, including to at least 12 Washington residents. The Statement of Charges further alleges that Respondent Mrachek acted as an unregistered broker-dealer and/or securities salesperson, and 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 registration, broker-dealer and/or securities salesperson registration and anti-fraud provisions of the Securities Act of Washington. The Securities Division gave notice of its intent to collect fines and charge costs. Respondents have a right to request a hearing on the Statement of Charges.

A Consent Order as to Gregory D. Mrachek was entered on October 23, 2018.


Berknell Financial Group, LLC - S-18-2432-18-CO01 - Consent Order

On May 31, 2018, the Securities Division entered Consent Order S-18-2432-18-CO01 with Berknell Financial Group, LLC (“Consent Order”). In the Consent Order Berknell (IARD 281662) agreed to cease and desist from violating the Washington Securities Act by acting as an unregistered investment adviser. Respondent also agreed to pay a fine. Respondent waived its right to a hearing and judicial review of the matter.


Larada Sciences, LLC. - S-17-2283-18-CO01 - Consent Order

On May 23, 2018, the Securities Division entered into a Consent Order with Larada Sciences, LLC (the “Respondent”). In the Consent Order, it is alleged that the Respondent violated the Franchise Investment Protection Act by offering unregistered franchises in Washington and failing to provide all of the basis and material assumptions for financial performance representations made. The Respondent has agreed to cease and desist from violations of RCW 19.100.020 and RCW 19.100.170, the registration and violations sections of the Franchise Investment Protection Act. Respondent agreed to pay $9,725 towards the costs of the investigation. The Respondent agreed to waive its right to a hearing and judicial review of the matter.


Roanan Corporation, Walter A. Moa Jr., James E. Fritz – S-15-1783-18-FO01 - Final Order

On May 17, 2018, the Department of Financial Institutions entered a Final Decision & Order (“Order”) against Respondents, Walter A. Moa Jr. (“Moa”), James E. Fritz (“Fritz”), and Roanan Corporation. The Order found that Respondents offered and sold approximately $775,000 worth of promissory note investments to approximately 40 investors. The Order found that Moa and Fritz violated RCW 21.20.040, the securities salesperson registration section of the Securities Act of Washington. The Order found that each of the Respondents violated RCW 21.20.140, the securities registration section, and RCW 21.20.010, the anti-fraud section. The Order imposed a fine of $25,000 and costs of $5,000 on Moa and a fine of $5,000 and costs of $2,500 on Fritz. The Respondents each have the right to petition the superior court for judicial review of the order.


Robert Thomas Kelly; Better Fuel Group NW, Inc. - S-14-1479-18-CO02 - Consent Order

On May 9, 2018, the Securities Division entered into a Consent Order with Robert Thomas Kelly and Better Fuel Group NW, Inc. (“Respondents”). The Securities Division had previously entered a Statement of Charges and Notice of Intent To Enter Order To Cease and Desist and To Impose Civil Penalties against Respondents on June 1, 2017 (“Statement of Charges”). In the Statement of Charges, the Securities Division alleged that Robert Thomas Kelly sold at least $229,750 in stock and promissory notes in two other respondent entities. Furthermore, the Statement of Charges alleged that Respondents sold at least $422,000 in business opportunities. The Statement of Charges alleged that Respondents sold these investments using a purported renewable fuel that another respondent, Timothy Dion Wetzel, claimed to have invented. Almost all, if not all, of these investors have lost their investments. The Securities Division alleged that the offer and sale of these investments were in violation of the registration and anti-fraud sections of the Securities Act of Washington and the Business Opportunity Fraud Act of Washington (collectively, the “Acts”). Without admitting or denying the Securities Divisions’ allegations, Respondents have agreed to cease and desist from violating the Acts. In addition, Robert Thomas Kelly has agreed to pay a fine of $3,500 and investigative costs of $1,500. Respondents waived their right to a hearing and judicial review of this matter.


Vincent Charles Palmer - S-17-2328-18-FO01 - Final Order

On May 9, 2018, the Securities Division issued a Final Order against Victor Charles Palmer (“Palmer”). On March 9, 2018, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist (the “Statement of Charges”) against Palmer. The Statement of Charges alleged that Palmer sold a toolkit, training, and marketing assistance to a Washington resident that would enable him to start a business unlocking cars for stranded motorists. In doing so, the Statement of Charges alleged that Palmer violated the registration and anti-fraud sections of Washington’s Business Opportunity Fraud Act (the “Act”). Palmer did not make a timely request for an administrative hearing on the Statement of Charges. The Final Order orders Palmer to cease and desist from violating the Act. Palmer may request judicial review of the Final Order.


Myung Ro - S-16-2044-18-FO01 - Final Order

On May 2, 2018, the Securities Division entered an Entry of Findings of Fact and Conclusions of Law and Final Order to Cease and Desist, to Impose a Fine, and to Charge Costs (“Final Order”) against Respondent Myung Ro. The Securities Division had previously issued a combined Summary Order against Respondent Myung Ro and his son Daeil Ro, a Washington-based financial advisor. In 2002, Daeil and Myung Ro convinced one of Daeil Ro’s clients to invest $2 million in commercial properties in South Korea. Myung Ro diverted approximately $320,000 of the client’s $2 million to purchase a house in Kent for himself and Daeil Ro, and Daeil and Myung Ro conspired to hide the misappropriation of funds from the client until the client filed a lawsuit in 2014. The Final Order orders Myung Ro to cease and desist from violating RCW 21.20.010 and to pay a fine and costs. Myung Ro has a right to request judicial review of the Final Order.


Kwench Juice Franchising Inc. - S-18-2418-18-SC01 - Statement of Charges

On May 1, 2018, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist (“Statement of Charges”) against Kwench Juice Franchising Inc. (“Kwench Juice”). The Statement of Charges alleges that Kwench Juice offered franchises in Washington State without being registered, in violation of RCW 19.100.020, the registration provision of the Franchise Investment Protection Act of Washington. The Securities Division intends to order Kwench Juice to cease and desist from violating RCW 19.100.020. Kwench Juice has a right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on June 14, 2018.


NEAT Method, Inc., now known as AMM Holdings, Inc. – S-18-2396-18-CO01 - Consent Order

On April 26, 2018, the Securities Division entered into a Consent Order with NEAT Method, Inc., now known as AMM Holdings, Inc. (“Respondent”). In the Consent Order, the Securities Division alleged that Respondent violated the Franchise Investment Protection Act (“FIPA”) by offering and selling a franchise to two Washington business partners while not registered to do so, and by failing to provide them with a franchise disclosure document. Without admitting or denying the Securities Division’s allegations, Respondent agreed to cease and desist from the registration and disclosure document sections of FIPA. The Respondent agreed to pay investigative costs of $500 and waived its right to a hearing and judicial review of the matter.


Morgan Henning a/k/a Morgan Rothschild and Party Princess International, LLC - S-17-2288-18-SC01 - Statement of Charges

On April 20, 2018, the Securities Division issued Statement of Charges No. S-18-2288-18-SC01 against Morgan Henning a/k/a Morgan Rothschild and Party Princess International, LLC, alleging that they violated the registration and disclosure document provisions of the Franchise Investment Protection Act of Washington in connection with their offer and sale of Party Princess International franchises in Washington. The Securities Division also alleges that Morgan Henning and Party Princess International further violated the Franchise Investment Protection Act by making misleading statements to prospective franchisees about the profitability of owning a Party Princess International franchise in Washington The Securities Division intends to order that Morgan Henning and Party Princess International cease and desist from violating the Franchise Investment Protection Act. Morgan Henning and Party Princess International each have a right to request a hearing on the Statement of Charges.


Off-Leash K9 Training, LLC and Gregory R. White - S-18-2403-18-CO01 - Consent Order

On April 18, 2018, the Securities Division entered into a Consent Order, Order No. S-18-2403-18-CO01, with Respondents, Off-Leash K9 Training, LLC and Gregory R. White. The Securities Division alleged that in 2015 and 2017, Respondents offered and sold two unregistered franchises that were located in the state of Washington. The Securities Division also alleged that Respondents failed to provide the franchisees with a Franchise Disclosure Document prior to selling the two franchises. The Respondents neither admitted nor denied the allegations, but agreed to cease and desist from violating the Franchise Investment Protection Act of Washington. Off-Leash K9 Training, LLC paid investigative costs of $1,000. The Respondents each waived their right to a hearing and to judicial review of the matter.


Joseph Zapata, d/b/a Redsolutions - S-17-2293-18-CO01 - Consent Order

On April 18, 2018, the Securities Division entered into a Consent Order with Joseph Zapata (“Zapata”), d/b/a Redsolutions. Redsolutions is a commercial coffee route and equipment provider. The Securities Division alleged that in 2017, Zapata violated the Business Opportunity Fraud Act, RCW 19.100, by offering an unregistered business opportunity. The Securities Division also alleged that Zapata violated the Business Opportunity Fraud Act by making misleading statements and by failing to disclose material risks about the business opportunity that was offered. Without admitting or denying the Securities Division’s allegations, Zapata agreed to cease and desist from any violation of the Business Opportunity Fraud Act. Zapata waived his right to a hearing and to judicial review of the matter.


LeVan Group, LLC d.b.a. BlackBall Dessert House and Black Ball Taiwanese Desserts, LLC; Nathan C. Van f.k.a. Nghia Van and d.b.a. Blackball Franchising, LLC; and Huong T. Le a.k.a. Nancy Le - S-18-2393-18-CO01 - Consent Order

On April 10, 2018, the Securities Division entered into a Consent Order with LeVan Group, LLC d.b.a. BlackBall Dessert House and Black Ball Taiwanese Desserts, LLC; Nathan C. Van f.k.a. Nghia Van and d.b.a. Blackball Franchising, LLC; and Huong T. Le a.k.a. Nancy Le (the “Respondents”). In the Consent Order, it is alleged that the Respondents violated the Franchise Investment Protection Act by offering unregistered franchises in Washington in 2016 and failed to disclose material facts about the offering. The Respondents have agreed to cease and desist from violations of RCW 19.100.020 and RCW 19.100.170, the registration and violations sections of the Franchise Investment Protection Act. Respondents agreed to pay $2,600 towards the costs of the investigation. The Respondents agreed to waive their right to a hearing and judicial review of the matter.


Gerald A. Hoye - S-17-2261-18-CO01 - Consent Order

On March 21, 2018, the Securities Division entered into a Consent Order with Respondent Gerald A. Hoye (“Hoye”). In the Consent Order, the Securities Division alleged that Hoye violated the registration and anti-fraud provisions of the Securities Act of Washington by offering and selling unregistered securities, by failing to update his Form U4, by failing to disclose his stock compensation for the sale of Nano-Green Biorefineries Inc. investments, and by omitting to state material facts regarding the investments. Without admitting or denying the Securities Division’s allegations, Hoye agreed to cease and desist from violating the Securities Act. Hoye also agreed to a denial of any future application for registration as a broker-dealer, securities salesperson, investment adviser, or investment adviser representative. Hoye paid a fine of $2,000. Hoye waived his right to a hearing and to judicial review of this matter.


Wendy’s International, LLC. - S-17-2358-18-CO01 - Consent Order

On March 16, 2018, the Securities Division entered into a Consent Order with Wendy’s International, LLC. (the “Respondent”). In the Consent Order, it is alleged that the Respondent’s franchise broker registration expired in December, 2015 and Respondent violated the Franchise Investment Protection Act by offering franchises in Washington in 2016 while not registered as a franchise broker. The Respondent has agreed to cease and desist from violations of RCW 19.100.140, the franchise broker registration section of the Franchise Investment Protection Act. Respondent agreed to pay $2,400 towards the costs of the investigation. The Respondent agreed to waive its right to a hearing and judicial review of the matter.


Randall Hayes - S-15-1636-17-SC01 - Statement of Charges

On March 14, 2018, the Securities Division issued a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Deny Registration, to Impose Fines, and to Charge Costs (Statement of Charges) against Randall Hayes.

The Statement of Charges alleges that Randall Hayes made unsuitable investment recommendations through the purchase of inverse and leveraged exchange-traded funds in a client account.

The Securities Division intends to order Randall Hayes to cease and desist from violating the Securities Act of Washington, to deny Randal Hayes’ future securities registrations, and to assess Randall Hayes fines and costs.

Randall Hayes has a right to request a hearing on the Statement of Charges.


Julia Williams, Advisory Services Group, Inc. - S-16-2106-17-SC01 - Statement of Charges

On March 14, 2018, 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 Julia Williams and Advisory Services Group, Inc., d/b/a ASG Accounting and Tax (collectively, “Respondents”). The Statement of Charges alleges that the Respondents violated the anti-fraud provisions of the Securities Act of Washington when they offered and sold more than $150,000 of investments to three investors. The Securities Division intends to order the Respondents to cease and desist from violating the Securities Act of Washington and gives notice of its intent to impose fines and to charge costs. Respondents each have a right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on August 8, 2018.


Wow Wow Hawaiian Lemonade Franchising, LLC - S-17-2349-17-CO01 - Consent Order

On March 13, 2018, the Securities Division entered into a Consent Order with Wow Wow Hawaiian Lemonade Franchising and Wow Wow, Inc. (“Respondents”). In the Consent Order, the Securities Division alleged that the Respondents violated the Franchise Investment Protection Act by offering and selling franchises to two state residents while not registered to do so, and by failing to provide prospective franchisees with a franchise disclosure document with current material information about the franchise offering. Without admitting or denying the Securities Division’s allegations, the Respondents agreed to cease and desist from the registration and disclosure document portions of the Franchise Investment Protection Act. The Respondents agreed to pay investigative costs of $500 and waived their right to a hearing and judicial review of the matter.


Ira Jay Weinstein - S-17-2296-18-CO02 - Consent Order

On March 13, 2018, the Securities Division entered into a Consent Order with Respondent Ira Jay Weinstein (“Weinstein”). In the Consent Order, the Securities Division alleged that Weinstein violated the registration and anti-fraud provisions of the Securities Act of Washington by offering and selling unregistered securities, by not being registered as a securities salesperson, by failing to update his Form U4, by failing to disclose his compensation for the sale of Woodbridge investments, and by omitting to state material facts regarding the investments. Without admitting or denying the Securities Division’s allegations, Weinstein agreed to cease and desist from violating the Securities Act. Weinstein also agreed to a one-year suspension of his investment adviser representative registration and not to apply for registration as a securities salesperson or broker-dealer for at least one year. Weinstein paid an initial fine of $500 and shall pay the remaining balance of $1500 within six months after the entry of the Consent Order. Weinstein waived his right to a hearing and to judicial review of this matter.


VI Capital Management, LLC and David Pointer - S-16-2093-17-CO01 - Consent Order

On March 12, 2018, the Securities Division entered a Consent Order S-16-2093-17-CO01 with VI Capital Management and David Pointer (“Consent Order”). VI Capital Management (CRD # 145310) is registered as an investment adviser and David Pointer (CRD # 3275105) is registered as an investment adviser representative of VI Capital Management. The Consent Order states that the Respondents failed to act in accordance with their fiduciary duty when they failed to fully and fairly disclose conflicts of interest and outside business activities and failed to timely distribute VI Capital’s year-end audited financial statements. The Consent Order further states that these acts violated RCW 21.20.020, RCW 21.20.110(1), WAC 460-24A-107(1), WAC 460-24A-205, WAC 460-24A-220. The Consent Order includes a $10,000 fine and costs of $2,500. The Securities Division and Respondents agreed to a revocation of VI Capital’s investment adviser registration and Dave Pointer’s investment adviser representative registration and restriction of future registrations. Respondents waived his right to request judicial review of the matter.


Daniel Langley; DGL Development, LLC; GetCarBids Inc. - S-17-2248-18-SC01 - Statement of Charges

On February 21, 2018 the Director of the Washington Department of Financial Institutions entered a Statement of Charges against Daniel Langley (“Langley”); DGL Development, LLC; and GetCarBids Inc. (“GetCarBids”) (collectively, “Respondents”). In the Statement of Charges, the Securities Division alleged that Respondents sold at least $535,300 in GetCarBids stock to at least 28 investors, at least 21 of whom were Washington residents, to start an online car auction website. The Securities Division also alleged that Langley spent the majority of investor funds on his personal expenses, including spending at the casino. The Securities Division alleged that the offer and sale of these investments were in violation of the registration and anti-fraud sections of the Securities Act of Washington.

The Statement of Charges gave notice of the Securities Division’s intent to order Respondents to cease and desist from violating the Securities Act, and to impose fines and to charge the cost of the investigation. Respondents have the right to request a hearing on the Statement of Charges


Community Impact Technologies, Inc. d/b/a Semble - S-16-2073-17-CO01 - Consent Order

On February 21, 2018, the Securities Division entered a Consent Order with Respondent Community Impact Technologies, Inc., d/b/a Semble (“Semble”). The Securities Division had previously entered a Statement of Charges and Notice of Intent to Order Cease and Desist, to Impose Fines, and to Charge Costs (“Statement of Charges”) against Respondent Community Impact Technologies, Inc. d/b/a Semble (“the Respondent”). In the Consent Order, the Securities Division alleged that, since approximately the beginning of 2012, Semble had engaged in the business of effecting transactions in securities for the account of others, without being registered as a broker-dealer. Without admitting or denying the Securities Division’s allegations, Semble agreed to cease and desist from violating the Securities Act, to pay $1,000 in fines, and to pay $1,000 in investigative costs. Semble agreed to waive its right to a hearing and judicial review of this matter.


New Leaf Holdings, Inc. – S-17-2326-18-CO01 - Consent Order

On February 21, 2018, the Securities Division entered into a Consent Order with New Leaf Holdings, Inc. The Securities Division alleged that New Leaf Holdings violated the registration and disclosure document provisions of the Franchise Investment Protection Act of Washington, in connection with the company’s sale of a hyperbaric oxygen therapy franchise to a Washington resident. Without admitting or denying the Securities Division’s allegations, New Leaf Holdings agreed to cease and desist from violating the Franchise Investment Protection Act of Washington. New Leaf Holdings further agreed to pay $1,000 in investigative costs and waived its right to a hearing and judicial review of the matter.


Brisk Management, LLC dba Heritage House Assisted Living – S-06-020-18-FO01 - Final Order

On February 20, 2018, the Securities Division issued an Entry of Findings of Fact and Conclusions of Law and Final Order to Cease and Desist, to Impose a Fine, and to Charge Costs (“Final Order”) against Respondent Brisk Management, LLC dba Heritage House Assisted Living (“Brisk Management”). The Securities Division previously entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist and to Impose Fines against Brisk Management and another respondent on March 12, 2007. Brisk Management sold unregistered securities to four investors and failed to disclose information material to the offerings in violation of the Securities Act of Washington. The Final Order orders Brisk Management to cease and desist from violating RCW 21.20.140 and RCW 21.20.010 and to pay a fine and costs. Brisk Management has a right to request judicial review of the Final Order.


Mitchell Johnson - S-17-2327-17-SC01 - Statement of Charges

On February 2, 2018, the Securities Division issued a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, to Suspend Registration, to Deny Registration, to Impose Fines, and to Charge Costs (Statement of Charges) against Mitchell R. Johnson.

The Statement of Charges alleges that Mitchell R. Johnson submitted false Form U4 filings with the Securities Division by failing to document the full scope of his work with CLA USA as well as a past regulatory action as a result of his work with CLA USA. The Statement of Charges further alleges that Mitchell R. Johnson failed to file an updated or amended Form U4 to document his ongoing work with CLA USA.

The Securities Division intends to order Mitchell R. Johnson to cease and desist from violating the Securities Act of Washington, to suspend Mitchell R. Johnson’s registration as an investment adviser representative, and to assess Mitchell R. Johnson fines and costs.

Mitchell R. Johnson has a right to request a hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on July 24, 2018.


Infinium Realty Group, Inc.; Ronald F. Westman; Robert R. Stevens - S-18-2367-18-CO01 - Consent Order

On 01/31/2018, the Securities Division entered into a Consent Order, Order No. S-18-2367-18-CO01, with Respondents, Infinium Realty Group, Inc., d/b/a Help-U-Sell (“Infinium”); Ronald F. Westman; and Robert R. Stevens. The Securities Division alleged that in 2016 Respondents offered and sold an unregistered franchise in Washington for an initial franchise fee of $17,750. The Respondents neither admitted nor denied the allegations, but agreed to cease and desist from violating the Franchise Investment Protection Act of Washington. Infinium paid investigative costs of $1,000. The Respondents each waived their right to a hearing and to judicial review of the matter.


Mark Allan Miller – S-16-2105-17-SC01 - Statement of Charges

On January 23, 2018, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, Deny Future Registrations, and Impose Fines (“Statement of Charges”) against Respondent Mark Allan Miller (“Miller”), CRD #4260127. In the Statement of Charges, the Securities Division alleges that Miller, a former registered investment adviser representative and securities salesperson in the Vancouver area, violated the Securities Act of Washington by making false filings with the Securities Division, engaging in outside business activities without notice to his firm or the Securities Division, and holding himself out as a financial planner while unlicensed to do so. The Statement of Charges gives notice of the Securities Division’s intent to enter an order to cease and desist, to impose fines of $40,000, to charge costs of $6,000, and to deny any future investment adviser representative or securities salesperson applications for registration. Miller has a right to request a hearing on the Statement of Charges.


Masters United 12 LLC – S-16-1943-17-CO01 - Consent Order

On January 18, 2018, the Securities Division entered a Consent Order with Respondents Masters United 12 LLC; United Partners – Ballard LLC; United Partners – Bellevue LLC; United Partners – Kent LLC; United Partners – Kirkland LLC; United Partners – Mercer Island LLC; United Partners – Mill Creek LLC; United Partners – Redmond LLC; Kris Eszlinger; and Preston Ducati (collectively “Respondents”). In the Consent Order, the Securities Division alleged that the Respondents had violated the Securities Act of Washington by offering and selling unregistered securities in the form of LLC membership interests, selling these securities while being unregistered to do so, and omitting material facts in connection with the offer and sale of these securities. Without admitting or denying the Securities Division’s allegations, the Respondents agreed to cease and desist from violating the Securities Act, to pay $2,500 in fines, and to pay $2,500 in investigative costs. The Respondents agreed to waive their right to a hearing and judicial review of this matter.


Shawn Anthony Mesaros; PAMRIA LLC - S-17-2348-18-CO01 - Consent Order

On January 19, 2018, the Securities Division entered into a Consent Order with Respondents PAMRIA LLC (“PAMRIA”) and Shawn Anthony Mesaros (“Mesaros”). The Securities Division had previously entered a Statement of Charges and Summary Order Suspending Investment Adviser Registration and Investment Adviser Representative Registration and Notice of Intent to Revoke Registration and Enter Order to Cease and Desist, Deny Future Registrations, Impose Fines, and Recover Costs against PAMRIA and Mesaros. In the Consent Order, the Securities Division alleges that Respondents failed to update Form U4 and Form ADV filings with the Securities Division, as required, to reflect Mesaros’s unsatisfied judgments, suspension from Financial Industry Regulatory Authority (“FINRA”) membership, and liability in an arbitration claim involving an investment business. The Consent Order also alleges that Respondents filed a Form ADV with the Securities Division that falsely represented that Mesaros did not have any unsatisfied judgments, a suspension from FINRA membership, and a liability in an arbitration claim involving an investment business. The Consent Order further alleges that PAMRIA failed to notify the Securities Division when there was a change in its ownership.

Without admitting or denying the Securities Division’s allegations, Respondents have agreed to the following: the investment adviser representative registration of Mesaros and the investment adviser registration of PAMRIA were suspended from December 12, 2017 until the entry of this Consent Order; Respondents shall each cease and desist from violation of RCW 21.20.350 and WAC 460-24A-205; Respondents shall pay fines and costs; and PAMRIA shall disclose this Consent Order in its ADV Part 2 until at least January 12, 2028. Respondents waived their rights to a hearing and judicial review of this matter.


Redsolutions; Joseph Zapata - S-17-2293-18-SC01 - Statement of Charges

On 01/11/2018, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist (“Statement of Charges”) against Joseph Zapata (“Zapata”), d/b/a Redsolutions. Redsolutions holds itself out as a commercial coffee route and equipment provider. The company’s Internet website lists an office address in Irvine, California.

The Statement of Charges alleges that in 2017, Zapata violated the Business Opportunity Fraud Act, RCW 19.100, by offering an unregistered business opportunity. The Statement of Charges also alleges that Zapata violated the Business Opportunity Fraud Act by making untrue and misleading statements and by failing to disclose material risks about the business opportunity that was offered. The Statement of Charges gives notice of the Securities Division’s intent to order Zapata, d/b/a Redsolutions, to cease and desist from violating the Business Opportunity Fraud Act. Zapata may request an administrative hearing on the Statement of Charges.

A Consent Order was entered regarding this matter on April 18, 2018.


Michael Louis Stokes, Sr. - S-16-1958-17-CO02 - Consent Order

On January 4, 2018, the Securities Division entered into a Consent Order with Michael Louis Stokes, Sr. (“Stokes”). On June 29, 2017, the Securities Division issued a Statement of Charges against Aegis Oil, LLC, Aegis Disposal Systems, LLC, Patrick Reagan Beason, Ranald James Moran, III, Michael Louis Stokes, Sr., Thierry Jean Hennequin, Mark David Long, and Frank August (“Respondents”). The Statement of Charges alleged that Respondents offered and sold approximately $1.5 million of unregistered securities to twelve Washington investors in violation of the registration and anti-fraud provisions of the Securities Act of Washington. Without admitting or denying the Division’s allegations, Stokes agreed to cease and desist from violating the Securities Act of Washington. Stokes waived his right to a hearing and judicial review in this matter.


Columbia Wealth Management, LLC; Patrick John Costello - S-17-2291-17-CO01 - Consent Order

On January 3, 2018, the Securities Division entered into a Consent Order with Columbia Wealth Management, LLC and Patrick John Costello (collectively “Respondents”). The Securities Division had previously entered a Summary Order Suspending Investment Adviser Registration and Investment Adviser Representative Registration and Notice of Intent to Revoke Registration, and Enter Order to Cease and Desist, Deny Future Registrations, Impose Fines, and Recover Costs against the Respondents on October 6, 2017. The Securities Division alleged that Respondents failed to update Form U4 and Form ADV filings with the Securities Division, as required, to reflect certain criminal charges and convictions filed against Patrick John Costello. The Securities Division also alleged that Respondents filed a Form ADV with the Securities Division that falsely represented that Patrick John Costello had not been charged with or convicted of certain criminal charges. Without admitting or denying the Securities Division’s allegations, Respondents agreed to cease and desist from violating the Securities Act of Washington. The Securities Division ordered that the registrations of Columbia Wealth Management as an investment adviser and Patrick John Costello as an investment adviser representative be revoked. The Securities Division further ordered that any future registration applications the Respondents may file in the future will be denied. Respondents waived their right to a hearing and judicial review of this matter.


Steven Hugh Minnich – S-14-1603-17-CO13 - Consent Order

On January 3, 2018, the Securities Division entered into a Consent Order with Respondent Steven Hugh Minnich (“Minnich”). The Securities Division previously entered a Statement of Charges against Minnich and various other respondents on March 7, 2016.

In the Statement of Charges, the Securities Division alleged that Minnich 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, Minnich agreed to cease and desist from violating the Securities Act of Washington, to pay a fine of $1,000 and to pay investigative costs of $250. Minnich waived his right to a hearing and judicial review of this matter.


Lisa Peake – S-17-2244-17-CO01 - Consent Order

On January 3, 2018, the Securities Division entered a Consent Order with Respondent Lisa Peake (“Peake”), CRD #1606662. The Securities Division had previously entered a Statement of Charges against Peake relating to the sale of a client list without notification to, or authorization from, her clients. In the Consent Order, Peake neither admitted nor denied the Securities Division’s Findings of Fact and Conclusions of Law, but agreed to cease and desist from violating the Securities Act of Washington’s accompanying regulations and to pay a fine of $6,000 and investigative costs of $1,000. Peake waived her right to a hearing and to judicial review of this matter.