↓ Skip to Main Content
SEC ACTIONS
  • Home
  • Articles
  • Archives
  • Media
  • Related Links
  • About
  • Subscribe to our Mailinglist
Home › SECActions ›

Former Registered Rep and Adviser Sanctioned For Statements Re Qualifications

Former Registered Rep and Adviser Sanctioned For Statements Re Qualifications

T. GormanPosted on October 12, 2023 Posted in SECActions

Broker-dealers and investment advisers are subject to a number of restrictions regarding marketing and advertising their services. In contrast, those who are not registered but acting as, for example, an unregistered investment adviser, are not subject to the same restrictions. This does not mean, however, that an unregistered adviser has no constraints on advertising. A recent case filed by the Commission, illustrates the point. In the Matter of Collaborative Financial Consulting LLC, Adm. Proc. File No. 3-21782 (October 11, 2023).

Collaborative Financial is a limited liability company based in Beverly Hills, California. The firm is not registered with the Commission or any other agency. Jason Reynolds has been the sole member of Collaborative from January 7, 2016, to the present. Previously, he was a registered representative and investment adviser associated with a registered representative and investment advisers.

In June 2019 Respondent Reynolds resigned his positions as a registered representative and investment adviser. His registration was terminated. The next month Mr. Reynolds began using Collaborative to conduct business as an unregistered investment adviser and financial planner. He also provided other services such as tax preparation and health insurance.

For a fee, Mr. Reynolds and his firm met personally with clients. During the meetings advise was furnished on stocks traded on national exchanges. Typically, after the meeting the clients placed securities purchase or sell orders through a broker. In some instances, Mr. Reynolds used the clients’ information to place and execute the transactions. Over a two-year period, beginning in 2019, Respondents received fees of at least $150,000 from eleven clients in several states for providing investment advice.

During the period Mr. Reynolds provided clients a document titled Client Agreement. It described the services being rendered. It also stated that Mr. Reynolds holds Series 7, 66, and 65 licenses in several states. He knew at the time the agreements were provided to the clients that those licenses had been terminated. The Order alleges violations of Advisers Act Section 206(2).

To resolve the proceedings Respondents consented to the entry of cease-and-desist orders based on the Section cited in the Order. In addition, Mr. Reynolds is barred essentially from the securities business but may apply for reentry after three years. The firm is censured. Mr. Reynolds will also pay a penalty of $20,000. That penalty is deemed satisfied by the amount paid in a parallel California state proceeding brought against each Respondent.

Print 🖨 PDF 📄
‹

Adviser Settles Conflicts Case

This Week In Securities Litigation (Week of October 16, 2023) ›
Tagged with: broker, investment adviser, no registration, SEC

Search SEC Actions

Prepared:

Thomas O. Gorman

DC Attorney specializing in securities
and other agency litigation

Former SEC Senior Counsel, Enforcement
and Special Trial Counsel, GC Office
    © 2025 SEC ACTIONS
    • Subscribe to our Mailinglist
    Manage Cookie Consent
    To provide the best experiences, we use technologies like cookies to store and/or access device information. Consenting to these technologies will allow us to process data such as browsing behavior or unique IDs on this site. Not consenting or withdrawing consent, may adversely affect certain features and functions.
    Functional Always active
    The technical storage or access is strictly necessary for the legitimate purpose of enabling the use of a specific service explicitly requested by the subscriber or user, or for the sole purpose of carrying out the transmission of a communication over an electronic communications network.
    Preferences
    The technical storage or access is necessary for the legitimate purpose of storing preferences that are not requested by the subscriber or user.
    Statistics
    The technical storage or access that is used exclusively for statistical purposes. The technical storage or access that is used exclusively for anonymous statistical purposes. Without a subpoena, voluntary compliance on the part of your Internet Service Provider, or additional records from a third party, information stored or retrieved for this purpose alone cannot usually be used to identify you.
    Marketing
    The technical storage or access is required to create user profiles to send advertising, or to track the user on a website or across several websites for similar marketing purposes.
    Manage options Manage services Manage {vendor_count} vendors Read more about these purposes
    View preferences
    {title} {title} {title}