Orders From Other Years

2024 | 2023 | 2022 | 2021 | 2020 | 2019 | 2018 | 2017 | 2016 | 2015 | 2014 | 2013 | 2012 | 2011 | 2010 | 2009 | 2008 | 2007 | 2006 | 2005 | 2004 | 2003 | 2002 and Earlier


Josette Santos - S-23-3598-24-SC01 - Statement of Charges

On February 14, 2024, the Securities Division entered a Statement of Charges and Notice of Intent to Deny Future Securities Registrations, to Impose Fines, and to Charge Costs against Josette Santos, CRD #6908112. The Securities Division alleged that Santos engaged in dishonest and unethical business practices in the securities business when she withdrew $1,000 without authorization from a customer bank account, when she obtained $2,000 from another customer without the customer’s knowledge, and when she forged a customer’s signature. The Securities Division gave notice of its intent to issue an order to the Respondent to deny any future securities registration. The Respondent has the right to request a hearing on the Statement of Charges.


Culichitown Management Group, Inc. and Ramón Misael Guerrero Elenes - S-23-3645-24-CO01 - Consent Order

On February 13, 2024, the Securities Division entered a Consent Order with Culichitown Management Group, Inc and Ramón Misael Guerrero Elenes (“Respondents”). The Securities Division alleged that Respondents offered and sold an unregistered franchise located in Tacoma, Washington. The Securities Division further alleged that the Respondents failed to provide the franchisee with a current disclosure document containing material information about the franchise. The Respondents agreed and were ordered to cease and desist from violations of RCW 19.100.020, the registration section of the Franchise Investment Protection Act and RCW 19.100.080, the disclosure document requirement section of the Franchise Investment Protection Act. The Respondents agreed to pay investigative costs of $1,156.25 and waived their right to a hearing and judicial review of the matter.


Coscoin LLC - S-23-3671-24-FO01 - Final Order

On February 12, 2024, the Securities Division entered a Final Order against Coscoin LLC. The Securities Division alleged that, between October 2023 and November of 2023, Washington Company Coscoin LLC offered and sold unregistered securities to at least 23 investors in amounts ranging from several hundreds to several thousands of dollars. The Securities Division alleged that the Respondent offered and sold unregistered Securities and violated the anti-fraud provision of the Securities Act. The Securities Division ordered the Respondents to cease and desist from violating the Securities Act of Washington. The Final Order orders Respondents to cease and desist from violating the Securities Act of Washington. The Respondents have a right to petition for judicial review of this matter.


ITP Corporation - S-23-3678-24-SC01 - Statement of Charges

On February 6, 2024, 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 ITP Corporation. The Securities Division alleged that, throughout the month of November of 2023, Washington Company ITP Corporation offered and sold unregistered securities to at least 6 investors in amounts ranging from several hundreds to several thousands of dollars. The Securities Division alleged that the Respondent offered and sold unregistered Securities and violated the anti-fraud provision of the Securities Act. The Securities Division ordered the Respondents to cease and desist from violating the Securities Act of Washington. The Securities Division gave notice of its intent to collect fines and charge costs. The Respondents have a right to request a hearing on the Statement of Charges.


Robinhood - S-21-3141-23-CO01 - Consent Order

On January 30, 2024, the Securities Division entered into a consent order with Respondents Robinhood Financial LLC as part of a multistate settlement to resolve the Securities Division’s investigation into Robinhood’s operational failures with respect to the retail market. The investigation was sparked by Robinhood platform outages in March 2020, a time when hundreds of thousands of investors were relying on the Robinhood app to make trades. In addition, prior to March 2021, there were deficiencies at Robinhood in its review and approval process for options and margin accounts, weaknesses in the firm’s monitoring and reporting tools, and insufficient customer service and escalation protocols that in some cases left Robinhood users unable to process trades even as the value of certain stocks was dropping. In Washington, Robinhood acquired approximately 107,972 new customers from October 1, 2019, to March 31, 2020. Robinhood approved approximately 21,702 Washington customers for option trading and approximately 3,918 Washington customers for margin trading.

In addition to a monetary settlement of $200,000 to the WA DFI, Respondents shall provide the Securities Division with a written attestation that the firm fully complied with the independent third-party consultant’s recommendations or has otherwise maintained measures as or more effective at addressing the purpose of the recommendations within one-year of the settlement date. Additionally, beginning in September 2023, Robinhood now offers live phone support for all inquiries to customers from 7:00 a.m. to 9:00 p.m. Eastern Time, 7 days a week. It is also available 24 hours a day, 7 days a week in more limited use cases.


Fresh Delivery LLC; Fresh Meal Holdings Inc.; and Nisha Ramakrishnan - S-23-3647-23-CO01 - Consent Order

On January 16, 2024, the Securities Division entered into a Consent Order with Fresh Delivery LLC; Fresh Meal Holdings Inc.; and Nisha Ramakrishnan (Respondents), a meal delivery business based in Issaquah, Washington. In the Consent Order, the Securities 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, the Respondents agreed to cease and desist from violating the Franchise Investment Protection Act. The Respondent agreed to pay investigative costs of $3,125 and waived its right to a hearing and judicial review of the matter.


Coscoin LLC - S-23-3671-23-SC01 - Statement of Charges

On January 9, 2024, 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 Coscoin LLC. The Securities Division alleged that, between October 2023 and November of 2023, Washington Company Coscoin LLC offered and sold unregistered securities to at least 23 investors in amounts ranging from several hundreds to several thousands of dollars. The Securities Division alleged that the Respondent offered and sold unregistered Securities and violated the anti-fraud provision of the Securities Act. The Securities Division ordered the Respondents to cease and desist from violating the Securities Act of Washington. The Securities Division gave notice of its intent to collect fines and charge costs. The Respondents have a right to request a hearing on the Statement of Charges.

A Final Order was entered regarding this matter on February 12, 2024.


Coolvu Franchising Concepts, Inc. - S-23-3649-23-CO01 - Consent Order

On January 8, 2024, the Securities Division entered into a consent order with Respondent Coolvu Franchising Concepts, Inc. (“Respondent”). The Securities Division alleged that the Respondent offered and/or sold an unregistered franchise known as “Coolvu of Tacoma.” The Respondent neither admits nor denies the allegations, however agreed to the order to cease and desist from violations of RCW 19.100.020. The Respondent further agreed to pay investigative costs of $750 and waived its right to a hearing and judicial review of the matter. The Respondent is currently seeking franchise registration with the Securities Division.


Friendship Holding LLC - S-22-3483-23-CO01 - Consent Order

On January 5, 2024, the Securities Division entered a Consent Order and Order Vacating Order No. S-22-3483-23-FO01 (“Consent Order”) against Friendship Holding LLC (“Friendship Holding” or the “Respondent”), a New York-based company that offers and sells Chinese-style BBQ restaurant franchises. The Securities Division previously entered a Statement of Charges and Notice of Intent to Issue an Order to Cease and Desist (“Statement of Charges”) against Friendship Holding in May 2023. The Statement of Charges alleged that Friendship Holding sold an unregistered franchise to a Washington investor in 2019. The Statement of Charges further alleged that Friendship Holding failed to provide that investor with a Franchise Disclosure Document prior to the sale. In settling the matter, the Respondent neither admitted nor denied the allegations, but agreed to cease and desist from violating the Franchise Investment Protection Act of Washington and pay investigative costs of $750. The Respondent waived its right to a hearing and to judicial review of the matter.


Educator of Truth, and His or Her Successors, a corporation sole, d/b/a Educational Empowerment Corporation; Mark Laurence Donald Emerson – S-23-3552-23-SC01 - Statement of Charges

On January 5, 2024, the Securities Division entered a Statement of Charges and Notice of Intent to Enter Order to Cease and Desist, Impose Fines, and Charge Costs (“Statement of Charges”) against Respondents Educator of Truth, and His or Her Successors, a corporation sole, d/b/a Educational Empowerment Corporation (“EEC”) and Mark Laurence Donald Emerson (“Emerson”) (collectively, “the Respondents”). In the Statement of Charges, the Securities Division alleges that EEC and Emerson violated the registration provisions of the Securities Act of Washington in the offer of interests in EEC. As set forth in the Statement of Charges, EEC and Emerson advertised interests in EEC on EEC’s website, which was generally available to the public. These interests were not registered with the Securities Division or any other regulator, and EEC and Emerson have not demonstrated that they qualify for an exemption from securities registration. 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 a fine of $5,000 against both Emerson and EEC, and to charge investigative costs of $1,000 to the Respondents generally. The Respondents each have the right to request a hearing on the Statement of Charges.


Prime IV Hydration & Wellness Inc. - S-23-3663-23-CO01 - Consent Order

On January 4, 2024, the Securities Division entered into a Consent Order with Prime IV Hydration & Wellness Inc. (“Respondent”). The Consent Order alleged that the Respondent collected franchise fees prior to the opening of franchise locations in violation of Respondent’s permits issued pursuant to RCW 19.100.050. In settling the matter, the Respondent neither admitted nor denied the allegations, but agreed to cease and desist from violating the conditions set forth in their registration permits. The Respondent waived its right to a hearing and to judicial review of the matter.


Raymond James – S-23-3590-23-CO01 - Consent Order

On January 4, 2024, the Securities Division entered into a consent order with Respondents Raymond James & Associates, Inc. (“RJA”) and Raymond James Financial Services, Inc. (“RJFS”) as part of a multistate settlement to resolve the Securities Division’s investigation into Respondents minimum commission practices for equity transactions. The investigation revealed that Respondents took a commission on equity transactions in excess of 5% of the principal value, sometimes taking 100% of the proceeds from a customer’s sale. In Washington, Respondents executed about 3,521 transactions which included an unreasonable commission for services performed (i.e. in excess of 5% of the principal trade amount) totaling approximately $107,329.76. In addition to a monetary settlement of $100,000 to the WA DFI, Respondents agreed pay restitution plus interest to affected Washington customers in an amount no less than $122,506.29 and to attest that its policies and procedures have been enhanced to ensure that all commissions are fair and reasonable within 60 days after the effective date of DFI’s order. This attestation will include Raymond James’s certifying that it has established:

  • Compliance systems to prevent the imposition of unreasonable or unfair commissions;
  • Operational changes designed to ensure that, regardless of the principal amount of a transaction, commissions will not exceed 5%, in the absence of a documented exception; and
  • Systems that incorporate all equity transactions, regardless of the principal amount of the transaction, when identifying and reviewing potentially excessive commissions.