2020 Division of Securities Enforcement Actions

Orders From Other Years

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Solium Financial Services LLC - S-20-2839-20-CO01 - Consent Order

On January 23, 2020, the Securities Division entered into a Consent Order with Respondent Solium Financial Services LLC (SFS). In connection with an investigation conducted by a multi-state taskforce of members of the North American Securities Administrators Association, the Securities Division alleged that from at least January 2009 to June 17, 2019, SFS acted as an unregistered broker-dealer in violation of RCW 21.20.040(1) when it transmitted orders for employee-participants residing in Washington as part of its equity plan administration software service for employers. SFS, without admitting or denying the findings of fact and conclusions of law, agreed to cease and desist from violations of RCW 21.20.040(1) and to pay $33,303.02 in fines and $450.00 in registration fees. SFS waived its right to a hearing and to judicial review of the matter.


American Beef Operations, LLC - S-19-2751-20-CO01 - Consent Order

On January 22, 2020, the Securities Division entered into a Consent Order with Respondent American Beef Operations, LLC. The Respondent’s principal place of business is Mercer Island, Washington. In the Consent Order, the Securities Division alleged that the Respondent offered and sold approximately $5.3 million worth of unregistered ABO LLC membership interests to more than 100 investors, including many Washington investors. The Securities Division alleged that the Respondent misrepresented the likely return on the investment and failed to disclose material information about the investment. Without admitting or denying the Securities Division’s allegations, the Respondent agreed to cease and desist from violating the registration and anti-fraud provisions of the Securities Act of Washington. The Respondent also waived its right to a hearing and to judicial review of the matter.


MotoVentures, Inc. - S-19-2704-19-CO01 - Consent Order

On January 22, 2020, the Securities Division entered into a Consent Order with MotoVentures, Inc.

The Securities Division alleged that MotoVentures violated the registration and disclosure document provisions of the Franchise Investment Protection Act of Washington, in connection with the company’s sale of a motorcycle training franchise to two Washington residents.

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


iCRYO Franchise Systems LLC - S-19-2814-20-CO01 - Consent Order

On January 17, 2020, the Securities Division entered into a Consent Order with Respondent iCRYO Franchise Systems LLC (Respondent). The Respondent offers a franchise system for providing cryotherapy. The Respondent’s principal place of business is Houston, Texas. In the Consent Order, the Securities Division alleged that Respondent violated the Franchise Investment Protection Act by offering a franchise and providing financial performance representations that were outside the Franchise Disclosure Document and by failing to disclose material information about the franchise. Without admitting or denying the Securities Division’s allegations, the Respondent agreed to cease and desist from violating the disclosure provisions of the Franchise Investment Protection Act. The Respondent also agreed to pay investigative costs of $500 and waived its right to a hearing and judicial review of the matter.


Burgerim Group USA, Inc – S-20-2836-20-SO01 - Stop Order

On January 14, 2020, the Securities Division entered a Stop Order Revoking Effectiveness of Registration Statement against Burgerim Group USA, Inc. (“Respondent”). The Securities Division alleges that Respondent violated the Washington Franchise Investment Protection Act (“FIPA”) when it failed to amend its registration statement filed with the Securities Division within a reasonable time after the material adverse change in its financial condition and material change in its franchise disclosure document in light of its move to hire insolvency counsel to restructure its debts and appoint a Chief Restructuring Officer, and its intention to file Chapter 11 bankrupcy. The Securities Division also finds that this order is in the public interest, and the current disclosure document, as registered with the Securities Division would work or tend to work as a fraud upon purchasers. Respondent has the right to request a hearing on the Stop Order.


Patrick Lawrence Kane d/b/a Asveris - S-19-2603-20-SC01 - Statement of Charges

On January 8, 2020, the Securities Division Statement of Charges and Notice of Intent to Enter Order to Cease and Desist against Patrick Lawrence Kane d/b/a Asveris (“Respondent”). The Securities Division alleges that Respondent violated the Washington Franchise Investment Protection Act (“FIPA”) by offering franchises to Washington residents while not registered with the Division, and for making misleading financial performance representations while doing so. The Securities Division intends to order Respondent to cease and desist from violating the registration and violations sections of FIPA. Respondent has the right to request a hearing on the Statement of Charges.


Bonchon Franchise LLC - S-19-2760-19-CO01 - Consent Order

On January 6, 2020, the Securities Division entered into a Consent Order with Bonchon Franchise, LLC. In the Consent Order, the Securities Division alleged that Bonchon Franchise, LLC violated the Franchise Investment Protection Act of Washington by using a materially inaccurate Franchise Disclosure Document to sell its franchise. Without admitting or denying the Division’s allegations, Bonchon Franchise, LLC agreed to cease and desist from violating the Franchise Investment Protection Act, and to pay $250 towards the costs of the investigation. Bonchon Franchise, LLC agreed to waive their rights to a hearing and judicial review of this matter.