UNITED STATES SECURITIES AND EXCHANGE COMMISSION

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 George L. Taylor ("Respondent"). The Commission finds that George L. Taylor, is the CEO, founder, Chief Compliance Officer, and majority owner of Temenos Advisory, Inc. ("Temenos"), an investment adviser registered with the Commission. Taylor is also a registered representative of a broker-dealer that is not affiliated with Temenos. Taylor is registered as a General Securities Representative, a General Securities Principal, an Investment Company Products/Variable Contracts Principal, and a Uniform Securities Agent with the Financial Industry Regulatory Agency. On June 30, 2020, a final judgment was entered by consent against Taylor, permanently enjoining him from future violations of Sections 206(1) and (2) of the Advisers Act and Section 15(a) of the Exchange Act, and aiding and abetting violations of Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder, in the civil action entitled Securities and Exchange Commission v. George L. Taylor, et al., Civil Action Number 3:18-cv-01180, in the United States District Court for the District of Connecticut. The Commission's complaint alleged that Taylor and Temenos defrauded their advisory clients and prospective clients by steering the clients into unsuitable investments and by hiding commissions and other financial incentives that Temenos and Taylor were pocketing, on top of the advisory fees that the clients were paying for supposedly unbiased financial advice. Temenos and Taylor repeatedly downplayed or concealed risks, and overstated potential gains, associated with a series of illiquid private placements that they advised their clients and prospective clients to invest in. In so doing, Taylor and Temenos promoted the investments and pocketed commissions-a percentage of each client's investment-from the private placement companies, thereby illegally acting as unregistered broker-dealers.

Order

Bar (Permanent)

association with a broker, dealer, investment adviser, municipal securities dealer, municipal advisor, transfer agent, or NRSRO

Indefinite

7/14/2020

participating in any offering of a penny stock, including: acting as a promoter, finder, consultant, or agent

Indefinite

7/14/2020

UNITED STATES SECURITIES AND EXCHANGE COMMISSION

The United States Securities and Exchange Commission ("the Commission") alleges the following against Defendants Temenos Advisory, Inc. ("Temenos") and its principal, George L. Taylor ("Taylor") that Temenos is a Connecticut-based investment adviser and Taylor is the majority owner of Temenos and also holds several positions at the firm, including chief executive officer ("CEO"). From 2014 through 2017, Temenos and Taylor defrauded their advisory clients and prospective clients by steering the clients into unsuitable investments and by hiding commissions and other financial incentives that Temenos and Taylor were pocketing, on top of the advisory fees that the clients were paying for supposedly unbiased financial advice. Temenos and Taylor repeatedly downplayed or concealed risks, and overstated potential gains, associated with a series of illiquid private placements that they advised their clients and prospective clients to invest in. In so doing, Defendants promoted the investments and pocketed commissions-a percentage of each client's investment-from the private placement companies, thereby illegally acting as unregistered broker-dealers. Through their conduct, Temenos and Taylor violated the fiduciary duty that every investment adviser owes to its clients and prospective clients-to put client interests first, to deal with clients with the utmost honesty, to disclose all conflicts or potential conflicts of interest, and to use reasonable care in providing investment advice. Instead, Defendants ignored their clients' interests and biased their investment advice to put money in their own pockets. The advisory clients and other investors harmed by the Defendants included retail investors, and some of the harmed investors were senior citizens or individuals approaching retirement who invested money from their retirement funds or pension plans into the private investments recommended by the Defendants. In connection with steering clients into four private placement investments, Temenos and Taylor breached their fiduciary duty to advisory clients and prospective clients. Temenos and Taylor also played an extensive role in soliciting the private placement investments in exchange for commissions from the private companies. In doing so, they illegally acted as unregistered broker-dealers when selling those investments. Through the activities alleged, Temenos and Taylor, while acting as investment advisers, have employed devices, schemes and artifices to defraud their investment advisory clients and have engaged in acts, transactions, practices and courses of businesses which operated as a fraud on their investment advisory clients, in violation of Sections 206(1) and (2) of the Investment Advisers Act of 1940 ("Advisers Act"). Temenos violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder by failing to implement its written valuation policy. Taylor aided and abetted that violation. And, Temenos and Taylor violated Section 15(a) of the Securities Exchange Act of 1934 ("Exchange Act") by inducing and attempting to induce the purchase and sale of securities without being registered as a broker or dealer or being associated with a registered broker or dealer.

Judgment Rendered

Civil and Administrative Penalty(ies)/Fine(s)

Disgorgement

$321,956.00

Monetary Penalty other than Fines

Injunction

undertakings

UNITED STATES SECURITIES AND EXCHANGE COMMISSION

civil and administrative, disgorgement. injunction and monetary penalty