Financial Enforcement Actions | Week of June 27 to July 03

Penalties: N/A
Respondent: Easydrive Cars Ltd
Violation: ECL has failed to comply with the regulatory requirement to submit the Return. ECL has not been open and co-operative in all its dealings with the Authority, in that ECL has failed to respond adequately to the Authority’s repeated requests for it to submit the Return, and has thereby failed to comply with Principle 11 of the Authority’s Principles for Businesses and to satisfy the Authority that it is ready, willing and organised to comply with the requirements and standards under the regulatory system. 8. These failures, which are significant in the context of ECL’s suitability, lead the Authority to conclude that ECL has failed to manage its business in such a way as to ensure that its affairs are conducted in a sound and prudent manner, that it is not a fit and proper person, and that it is therefore failing to satisfy the Threshold Conditions in relation to the regulated activities for which ECL was granted a Part 4A permission… Read More

Penalties: N/A
Respondent: Effen Ads
Violation: Sent misleading spam emails that linked to fake news stories and false celebrity endorsements… Read More

Penalties: $5,000.00
Respondent: Gregory A. Ricker
Violation: During the period of December 2017 through April 2018 (the “Relevant Period), Ricker participated in a private securities transaction by referring a potential investor (“A”) to a videogame media and news company (the “Company”) and receiving selling compensation in the amount of $75,000 for A’s $750,000 investment in the Company. Ricker participated in this private securities transaction without notifying, and receiving prior written approval from, Westpark, in violation of FINRA Rules 3280 and 2010… Read More

Penalties: N/A
Respondent: Michael J. Iannarino
Violation: Iannarino failed to provide documents and information requested pursuant to FINRA Rule 8210. By virtue of this misconduct, Iannarino violated FINRA Rules 8210 and 2010… Read More

Penalties: $5,000.00
Respondent: Katie Ann Hudson
Violation: Between August 2013 and February 2019 (the “Relevant Period”), Respondent failed to timely amend her Uniform Application for Securities Industry Registration or Transfer (“Form U4”) to disclose that she had been charged with felonies on two occasions, in violation of Article V, Section 2(c) of the FINRA By-Laws and FINRA Rules 1122 and 2010… Read More

Penalties: $50,000.00
Respondent: Silver Leaf Partners, LLC
Violation: Silver Leaf’s new Morrison argument, Enforcement withdrew some of its allegations relating to the payments to the unregistered finder. In its posthearing brief, Enforcement stated that it no longer sought to hold Silver Leaf liable for payments to SH in connection with the two stock loan transactions for BHP. 5 Enforcement did not withdraw its allegations that the payment to SH in connection with the block trade for another customer violated NASD 2420 or that the payments to the Nonmember Entities violated NASD Rule 2420. Nor did Enforcement withdraw its allegation that the payments to SH were evidence of Silver Leaf’s alleged supervisory failures. Member firm failed to establish and maintain a supervisory system reasonably designed to achieve compliance with applicable securities laws, regulations, and FINRA rules, and paid transaction-based compensation to nonmember brokers. Held, findings affirmed and sanctions modified… Read More

Penalties: $7,500.00
Respondent: Henry A. Taylor III
Violation: “In February 2017, Taylor violated FINRA Rules 3280 and 2010 by participating in a $30,000 private securities transaction without notifying Cetera. Taylor’s failure to provide the required notice to Cetera is aggravated by the fact that he concealed the investment from the firm. In mid-February 2017, Cetera learned that Taylor was either participating or contemplating participating in the trucking company investment. On February 16, 2017, Cetera warned Taylor that any such investment would constitute a prohibited private securities transaction that could result in his termination. Taylor falsely denied making any investment and falsely disavowed any intent to pursue any investment. By virtue of the foregoing, Taylor violated FINRA Rules 3280 and 2010… Read More

Penalties: N/A
Respondent: Christopher Peter Tranchina
Violation: Townsend & Kent (“HTK”) fired Christopher Peter Tranchina and instructed him not to return to the office, Tranchina broke into his locked office and stole client-related files belonging to HTK and its affiliated insurance company. Through his theft of this property, Tranchina committed conversion in violation of FINRA Rule 2010. The files that Tranchina stole related to HTK clients and prospective clients, and Tranchina had no authorization or right to take them. Tranchina accessed this information, which included firm customers’ names, addresses, telephone numbers, and email addresses, in an effort to take these customers with him to a new firm. By accessing HTK’s information without authorization, Tranchina violated FINRA Rule 2010… Read More

Penalties: $5,000.00
Respondent: John G. Kallis
Violation: Between September 2014 and December 2017 (the “Relevant Period”), Kallis participated in private securities transactions without providing prior written notice to LPL. Based on the foregoing, Kallis violated NASD Rule 3040 (for conduct prior to September 21, 2015), FINRA Rule 3280 (for conduct on or after September 21, 2015) and FINRA Rule 2010… Read More

Penalties: $7,500.00
Respondent: Avanza Capital Markets Inc.
Violation: From February 1, 2017 through May 24, 2019 (the “Relevant Periodl, Avanza failed to report to the Trade Reporting and Compliance Engine (” TRACE”) the customer leg of its riskless principal transactions in fixed income securities, in violation of FINRA Rules 6730 and 2010… Read More

Penalties: N/A
Respondent: Leonard J. Marzocco
Violation: Between November 2015 and December 2017 (the Relevant Period.), Marzocco excessively traded three customers’ accounts in violation of FINRA Rules 2111 and 2010… Read More

Penalties: $200,000.00
Respondent: Cadaret, Grant & Co., Inc.
Violation: “From April 2014 to March 2017 (the “”Relevant Period””), Cadaret Grant failed to reasonably supervise registered representative, SP, who conducted multiple undisclosed private securities transactions. The private securities transactions were part of a Ponzi scheme that SP orchestrated, which resulted in millions of dollars in losses to its victims,
including several customers of Cadaret Grant.2 The Firm failed to take reasonable steps to investigate red flags that SP was involved in private securities transactions. As a result of the foregoing, Cadaret Grant violated NASD Rule 3010 (for conduct before December 1, 2014), FINRA Rule 3110 (for conduct on or after December 1, 2014), and FINRA 2010… Read More

Penalties: $5,000.00
Respondent: Robert J. McNamara
Violation: “Between August 2017 and August 2018, McNamara exercised discretion without written authorization in 18 customer accounts, in violation of NASD Rule 2510(b) and FINRA Rule 2010. FINRA conducted an examination of Cadaret Grant between August 2017 and August 2018. During that period, McNamara effected at least 90 discretionary trades in 18 customer accounts. Although the customers knew that McNamara was exercising discretion in their accounts, McNamara did not have prior written authorization to do so from any of the customers. Additionally, Cadaret Grant had not approved any of the accounts for discretionary trading. By virtue of the foregoing, McNamara violated NASD Rule 2510(b) and FINRA Rule 2010… Read More

Penalties: $25,000.00
Respondent: Valmark Securities, Inc.,
Violation: Between June 2, 2016 and January 22, 2019, Valmark did not retain approximately 180,000 emails for 19 email users in 4 branch offices. As a result, the firm violated SEC Exchange Act Rule 17a-4 and FINRA Rules 4511 and 2010… Read More

Penalties: $5,000.00
Respondent: Timothy Patrick McLanahan
Violation: In an attempt to transfer the proceeds of a mutual fund account in accordance with a deceased client’s wishes, McLanahan altered a letter of authorization signed by his client directing the liquidation of mutual funds, and affixed a Medallion signature guarantee to the letter, in violation of FINRA Rules 2010 and 4511… Read More

Penalties: $5,000.00
Respondent: Eugene J. Long
Violation: During the period between August 2017 and August 2018, Long exercised discretion without written authorization in 64 customer accounts, in violation of NASD Rule 2510(b) and FINRA Rule 2010… Read More

Penalties: $25,000.00
Respondent: Valmark Securities, Inc.,
Violation: Between June 2, 2016 and January 22, 2019, Valmark did not retain approximately 180,000 emails for 19 email users in 4 branch offices. As a result, the firm violated SEC Exchange Act Rule 17a-4 and FINRA Rules 4511 and 2010… Read More

Penalties: $40,000.00
Respondent: PRIMEX PRIME ELECTRONIC EXECUTION, INC. d/b/a PRIMEX WILFREDO FELIX
Violation: Respondent Wilfredo Felix is barred in all capacities for failing to provide a personal tax-related document during the investigation of this matter. Felix and Primex made and preserved inaccurate and false expense records, causing Primex to maintain an inaccurate general ledger and file inaccurate quarterly FOCUS Reports. Primex also responded to a FINRA request for information and documents in an untimely manner. In light of the bar, no additional sanctions are imposed against Felix for the books and records violations. Enforcement failed to prove that Felix provided false or misleading information and testimony during the investigation. Those charges are therefore dismissed… Read More

Penalties: $350,000.00
Respondent: James E. Leeney
Violation: Based on the foregoing, the Commission finds that, during the Relevant Period, James E. Leeney violated Section 4c(b) of the Act, 7 U.S.C. § 6c(b) (2018), Section 4o of the Act, 7 U.S.C. § 6o (2018), and Regulation 33.10, 17 C.F.R. § 33.10 (2019)… Read More

Penalties: N/A
Respondent: Scott J. Gecas
Violation: Based on the foregoing, the Commission finds that, during the Relevant Period, Scott J. Gecas violated Section 4c(b) of the Act, 7 U.S.C. § 6c(b) (2018), Section 4o of the Act, 7 U.S.C. § 6o (2018), and Regulation 33.10, 17 C.F.R. § 33.10 (2019)… Read More

Penalties: N/A
Respondent: Long Leaf Trading Group, Inc., James A. Donelson, Timothy M. Evans, Jeremy S. Ruth, and Andrew D. Nelson
Violation: Long Leaf failed to make required customer disclosures relating to client accounts guided pursuant to a “systematic program that recommends specific trades,” in violation of Regulation 4.31(a) and (b), 17 C.F.R. § 4.31(a), (b) (2019). Long Leaf failed to file any such disclosures with the National Futures Association (“NFA”), in violation of Regulation 4.36(d)(1), 17 C.F.R. § 4.36(d)(1) (2019). 9. Certain LLT Defendants are liable for registration violations, including failure to register as a commodity trading advisor (“CTA”) under Section 4m(1) of the Act, 7 U.S.C. § 6m(1) (2018), and failure to register as associated persons (“APs”) under Section 4k(1) of the Act, 7 U.S.C. § 6k(1) (2018), and Regulations 3.12(a) and 33.3(b)(1) and (2), 17 C.F.R. §§ 3.12(a), 33.3(b)(1), (2) (2019)… Read More

Penalties: $250,000.00
Respondent: Cunningham Commodities, LLC
Violation: During the Relevant Period, Respondent failed to diligently supervise accounts in violation of Regulation 166.3, 17 C.F.R. § 166.3 (2019). Specifically, Respondent, through its officers, employees, and agents, missed indications that Entity A was defrauding customers through accounts carried by Respondent. Respondent allowed Entity A to continue introducing accounts and receiving commissions from trading in those accounts. Additionally, in March 2019, Respondent executed the Guarantee with Entity A pursuant to Regulation 1.17(a)(2)(ii), 17 C.F.R. § 1.17(a)(2)(ii) (2019). Accordingly, Respondent is jointly and severally liable with the Entity A for all restitution and disgorgement obligations imposed against Entity A in any related CFTC enforcement proceeding for Entity A’s conduct during the period of the Guarantee… Read More

Penalties: N/A
Respondent: Daniel C. Ustian
Violation: The Securities and Exchange Commission today announced that a court has barred the former CEO of Illinois-based Navistar International Corporation, Daniel C. Ustian, from serving as an officer or director of publicly-traded companies. The SEC charged Ustian, of Naperville, Illinois, and Navistar in 2016 with misleading investors about Navistar’s development of an advanced technology truck engine that could satisfy U.S. pollution standards. Navistar agreed to settle the SEC’s charges in 2016, and the SEC commenced federal court litigation against Ustian… Read More

Penalties: $91,810.33
Respondent: Dandan Wu
Violation: As a result of the conduct described above, Wu violated Section 10(b) of the Exchange Act and Rule 10b-5 thereunder, which prohibit fraudulent conduct in connection with the purchase or sale of securities… Read More

Penalties: N/A
Respondent: BNP Paribas Securities Corp.
Violation: BNPP loaned securities to the Hedge Fund to settle “long” sale orders while the Hedge Fund had outstanding loans of the same securities, which it had borrowed to settle prior “long” sales that previously had been submitted to BNPP for clearing. In light of the Hedge Fund’s conduct, it was unreasonable for BNPP to rely on the Hedge Fund’s statements that the Hedge Fund’s orders were properly marked “long” and that the Hedge Fund would deliver the securities to its BNPP account prior to scheduled settlement. Accordingly, BNPP could not avail itself of any exception to Rule 203(a)(1). 5. BNPP therefore violated Rule 203(a)(1) on at least 35 occasions when it loaned the Hedge Fund securities to settle sale orders marked as “long… Read More

Penalties: N/A
Respondent: John Christopher Polit
Violation: The Securities and Exchange Commission (“Commission”) deems it appropriate and in the public interest that public administrative proceedings be, and hereby are, instituted pursuant to Section 15(b) of the Securities Exchange Act of 1934 (“Exchange Act”) and Section 203(f) of the Investment Advisers Act of 1940 (“Advisers Act”) against John Christopher Polit (“Polit” or “Respondent”)… Read More

Penalties: $50,000.00
Respondent: Potamus Trading LLC and Eric J. Pritchett
Violation: As a result of the conduct described above, Respondents willfully violated Section 17(a)(2) of the Securities Act, which prohibits obtaining money or property in the offer or sale of securities by means of any untrue statement of a material fact or any omission to state a material fact necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading. As result of the conduct described above, Respondents willfully violated Section 17(a)(3) of the Securities Act, which prohibits, in the offer or sale of securities, engaging in any transaction, practice, or course of business which operates or would operate as a fraud or deceit upon the purchaser… Read More

Penalties: $171,836.00
Respondent: Apex Fund Services (US), Inc.,
Violation: According to the Order, the Managers made undisclosed withdrawals of more than $1 million directly from the Funds in violation of Sections 206(2) and 206(4) of the Investment Advisers Act of 1940 (“Advisers Act”) and Rule 206(4)-8 thereunder. The Commission found that Apex improperly classified these withdrawals as receivables without evidence that the Managers were able or willing to repay the withdrawals. The Commission further found that the improper classification of the withdrawals as assets resulted in the overstatement of the value of investor holdings in the Funds in monthly statements sent by Apex to investors. The Commission determined that, by this conduct, Apex was a cause of the Managers’ violations of Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-8 thereunder… Read More

Penalties: $275,000,000.00
Respondent: Morgan Stanley, Co. LLC; Morgan Stanley Abs Capital I Inc; and Morgan Stanley Mortgage Capital Holdings LLC
Violation: On July 24, 2014, the Commission issued an Order Instituting Cease and Desist Proceedings Pursuant to Section 8A of the Securities Act of 1933, Making Findings, and Imposing a Cease-and-Desist Order (“Order”) against Morgan Stanley and Co. LLC (f/k/a “Morgan Stanley and Co. Incorporated”) (“MS & Co.”), Morgan Stanley ABS Capital I Inc., (“MSAC”), and Morgan Stanley Mortgage Capital Holdings LLC, (“MSMCH”) (collectively, the “Respondents”)… Read More

Penalties: $119,360.00
Respondent: Michelle Dipp
Violation: Dipp violated Sections 17(a)(2) and (3) of the Securities Act which make it unlawful to obtain money or property through materially false or misleading statements and proscribe any transaction, practice, or course of business that operates or would operate as a fraud or deceit upon a purchaser of securities. Negligence is sufficient for liability under Sections 17(a) (2) and (3). OvaScience violated the reporting provisions of Section 13(a) of the Exchange Act and Rules 13a-1, 13a-11, 13a-13, and 12b-20 thereunder, by filing the following periodic and current reports on Forms 10-K, 10-Q, and 8-K that contained materially false or misleading statements regarding the availability and commercial prospects for the Company’s fertility treatments: 2014 Form 10-K filed March 16, 2015; 2015 Form 10K filed February 26, 2016; Form 10-Q for quarter ended March 31, 2015 filed May 11, 2015; Form 10-Q for quarter ended June 30, 2015 filed August 10, 2015; Forms 8-K filed or furnished on December 17, 2014, March 16, 2015, May 11, 2015, August 10, 2015, September 29, 2015, and December 7, 2015… Read More

Penalties: N/A
Respondent: Frank Bianco
Violation: The Securities and Exchange Commission (“Commission”) deems it appropriate and in the public interest that public administrative proceedings be, and hereby are, instituted pursuant to Section 203(f) of the Investment Advisers Act of 1940 (“Advisers Act”) against Frank Bianco (“Respondent”)… Read More

Penalties: N/A
Respondent: Consorteum Holdings, Inc. and Coates International Ltd.,
Violation: As discussed in more detail above, both Respondents are delinquent in their periodic filings with the Commission, have repeatedly failed to meet their obligations to file timely periodic reports, and failed to heed delinquency letters sent to them by the Division of Corporation Finance requesting compliance with their periodic filing obligations or, through their failure to maintain a valid address on file with the Commission as required by Commission rules, did not receive such letters. As a result of the foregoing, Respondents failed to comply with Exchange Act Section 13(a) and Rules 13a-1 and 13a-13 thereunder… Read More

Penalties: N/A
Respondent: Santa Fe Gold Corporation and Revolution Lighting Technologies, Inc.,
Violation: As discussed in more detail above, both Respondents are delinquent in their periodic filings with the Commission, have repeatedly failed to meet their obligations to file timely periodic reports, and failed to heed delinquency letters sent to them by the Division of Corporation Finance requesting compliance with their periodic filing obligations or, through their failure to maintain a valid address on file with the Commission as required by Commission rules, did not receive such letters. As a result of the foregoing, Respondents failed to comply with Exchange Act Section 13(a) and Rules 13a-1 and 13a-13 thereunder… Read More

Penalties: $80,000.00
Respondent: David Rumsey
Violation: As a result of Rumsey’s negligent conduct described above, Rumsey violated Section 17(a)(2) of the Securities Act, which prohibits, directly or indirectly, in the offer or sale of securities, obtaining money or property by means of any untrue statement of a material fact or any omission to state a material fact necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading. As a result of Rumsey’s negligent conduct described above, Rumsey violated Section 17(a)(3) of the Securities Act, which makes it unlawful for any person, in the offer or sale of any securities, directly or indirectly, to engage in any transaction, practice, or course of business which operates or would operate as a fraud or deceit upon the purchaser… Read More

Penalties: N/A
Respondent: Matthew Benjamin and Clear Solutions Group, LLC,
Violation: By virtue of the foregoing conduct and as alleged further herein, Defendants Benjamin and Clear Solutions have violated Section 17(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. § 77q(a)], Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. § 78j(b)], and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5]. 5. Unless Defendants are restrained and enjoined, they will engage in the acts, practices, transactions, and courses of business set forth in this Complaint or in acts, practices, transactions, and courses of business of similar type and object… Read More

Penalties: $350,000.00
Respondent: Franklin Advisers, Inc. and Franklin Templeton Investments Corp.
Violation: FAV willfully violated Section 206(4) and Rule 206(4)-7 of the Advisers Act, which require a registered investment adviser to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder. As a result of the conduct described above, FAV caused the Franklin Funds’ violations of Rule 38a-1(a) of the Investment Company Act, which requires that registered investment companies, among other things, adopt and implement written policies and procedures reasonably designed to prevent violation of the federal securities laws by the fund, including policies and procedures that provide for the oversight of compliance by the fund’s investment adviser… Read More

Penalties: $21,476,531.00
Respondent: Alexion Pharmaceuticals, Inc.
Violation: Alexion violated Section 13(b)(2)(A) of the Exchange Act, which requires issuers to make and keep books, records, and accounts which, in reasonable detail, accurately and fairly reflect their transactions and dispositions of the assets of the issuer. As a result of the conduct described above, Alexion violated Section 13(b)(2)(B) of the Exchange Act, which requires issuers to devise and maintain a system of internal accounting controls sufficient to provide reasonable assurances that (i) transactions are executed in accordance with management’s general or specific authorization; (ii) transactions are recorded as necessary (I) to permit preparation of financial statements in conformity with generally accepted accounting principles or any other criteria applicable to such statements, and (II) to maintain accountability for assets; (iii) access to assets is permitted only in accordance with management’s general or specific authorization; and (iv) the recorded accountability for assets is compared with the existing assets at reasonable intervals and appropriate action is taken with respect to any differences… Read More

Penalties: N/A
Respondent: Cyclone Power Technologies, Inc. and Ecolocap Solutions, Inc.,
Violation: “As discussed in more detail above, both Respondents are delinquent in their periodic filings with the Commission, have repeatedly failed to meet their obligations to file timely periodic reports, and failed to heed delinquency letters sent to them by the Division of Corporation Finance requesting compliance with their periodic filing obligations or, through their failure to maintain a valid address on file with the Commission as required by Commission rules, did not receive such letters. As a result of the foregoing, Respondents failed to comply with Exchange Act Section 13(a) and Rules 13a-1 and 13a-13 thereunder… Read More

Penalties: N/A
Respondent: Eos Petro, Inc. and eFleets Corporation
Violation: “As discussed in more detail above, both Respondents are delinquent in their periodic filings with the Commission, have repeatedly failed to meet their obligations to file timely periodic reports, and failed to heed delinquency letters sent to them by the Division of Corporation Finance requesting compliance with their periodic filing obligations or, through their failure to maintain a valid address on file with the Commission as required by Commission rules, did not receive such letters. As a result of the foregoing, Respondents failed to comply with Exchange Act Section 13(a) and Rules 13a-1 and 13a-13 thereunder… Read More

Penalties: N/A
Respondent: Matthew Benjamin and Clear Solutions Group, LLC
Violation: According to the SEC’s complaint, between 2017 and 2019, Benjamin and his purported cosmetics company, Clear Solutions Group, LLC, defrauded investors of approximately $900,000 by soliciting and selling securities to the investors using false and misleading statements. Specifically, the complaint alleges that Benjamin falsely told investors Clear Solutions was able to purchase cosmetics at wholesale prices and profitably resell them at a mark-up to a retailer. The complaint alleges that, in reality, Benjamin and Clear Solutions did not conduct any such business. Instead, Benjamin allegedly used investor funds for his own personal benefit. In August 2019, Benjamin confessed to several investors that his purported business was a sham designed to defraud them… Read More

Penalties: N/A
Respondent: Neil Burkholz
Violation: The Securities and Exchange Commission (“Commission”) deems it appropriate and in the public interest that public administrative proceedings be, and hereby are, instituted pursuant to Section 203(f) of the Investment Advisers Act of 1940 (“Advisers Act”) against Neil Burkholz (“Respondent” or “Burkholz”)… Read More

Penalties: $80,000.00
Respondent: David Rumsey
Violation: As a result of Rumsey’s negligent conduct described above, Rumsey violated Section 17(a)(2) of the Securities Act, which prohibits, directly or indirectly, in the offer or sale of securities, obtaining money or property by means of any untrue statement of a material fact or any omission to state a material fact necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading. As a result of Rumsey’s negligent conduct described above, Rumsey violated Section 17(a)(3) of the Securities Act, which makes it unlawful for any person, in the offer or sale of any securities, directly or indirectly, to engage in any transaction, practice, or course of business which operates or would operate as a fraud or deceit upon the purchaser… Read More

Penalties: N/A
Respondent: ERBA Diagnostics, Inc. and Eternity Healthcare, Inc.
Violation: As discussed in more detail above, both Respondents are delinquent in their periodic filings with the Commission, have repeatedly failed to meet their obligations to file timely periodic reports, and failed to heed delinquency letters sent to them by the Division of Corporation Finance requesting compliance with their periodic filing obligations or, through their failure to maintain a valid address on file with the Commission as required by Commission rules, did not receive such letters. As a result of the foregoing, Respondents failed to comply with Exchange Act Section 13(a) and Rules 13a-1 and 13a-13 thereunder… Read More

Penalties: N/A
Respondent: Gilla, Inc. and Evergreen-Agra Global Investments, Inc.
Violation: As discussed in more detail above, both Respondents are delinquent in their periodic filings with the Commission, have repeatedly failed to meet their obligations to file timely periodic reports, and failed to heed delinquency letters sent to them by the Division of Corporation Finance requesting compliance with their periodic filing obligations or, through their failure to maintain a valid address on file with the Commission as required by Commission rules, did not receive such letters. As a result of the foregoing, Respondents failed to comply with Exchange Act Section 13(a) and Rules 13a-1 and 13a-13 thereunder… Read More

Penalties: N/A
Respondent: Daniel Dirk Coddington, et al.
Violation: The SEC’s complaint, filed on December 12, 2013, alleges that Coddington defrauded investors by soliciting investments in Collateralized Mortgage Obligations (CMOs). Specifically, the complaint alleges that Coddington told investors that he would pledge the CMOs as collateral for loans, and then use the loan proceeds in a year-long trading program that would generate profits ranging from 250% to 475%. The complaint further alleges that the trading program did not exist, and that Coddington and others misappropriated the majority of investor money. According to the SEC’s complaint, Geisler and Gunn made false and misleading statements about the trading program to solicit investors and received hundreds of thousands of dollars for their efforts… Read More

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