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 Bradley J. Tennison ("Tennison" or "Respondent"). The Commission finds that on June 23, 2020, Tennison pleaded guilty to the attempted sale of unregistered securities, a felony, before the Superior Court, Maricopa County, Arizona, in State of Arizona v. Bradley J. Tennison, Case No. CR2019-002711-002 DT. The Superior Court entered a judgment of guilty against Tennison, sentenced him to supervised probation for a term of three years, and ordered him to pay restitution of $8,185,000. On January 22, 2021, the Arizona Corporation Commission ("ACC") in In the Matter of Frederick Arias, et al., Docket No. S-21078A-19-0143, entered a final order by consent against Tennison finding that Tennsion violated Sections 44-1841 (selling unregistered securities) and 44-1991 (making false statements) of the Securities Act of Arizona, revoking his Arizona securities salesman registration, revoking his investment adviser representative license, and ordering him to pay a $75,000 penalty. The conduct giving rise to Tennison's guilty plea and state revocation order involved Tennison's sale to nine investors, between October 2015 through September 2016, of unregistered securities in The Joseph Project, a supposed religious and humanitarian project for which Tennison served as the general manager. In connection with these sales, Tennison told investors falsely that the funds would be invested with banks that would use the investment proceeds for after-hours trading to generate returns; the investment was 100% safe; and that profits would be used, in part, for religious and humanitarian projects.

Order

Bar (Permanent)

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

Indefinite

5/4/2021

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

Indefinite

5/4/2021

Claimant allege that in 2016 Tennison recommended an investment in The Joseph Project, an alleged pooled investment vehicle and private placement offering that was not approved by Geneos. Claimants allege Tennison's recommendations were fraudulent and other causes of actions.

$600,000.00

$100,000.00

Arizona Corporation Commission Securities Division

Tennison has been the general manager of The Joseph Project since at least December 23, 2015. In connection with the offer or sale of securities within or from Arizona, Respondents Bradley Tennison, Frederick Arias and The Joseph Project falsely represented to certain Investors that: (1) The investment proceeds would be placed in a bank account and would remain in that account, (2) The investment proceeds would be used only as collateral, (3) The investment was 100% safe,(4) Banks would use the investment proceeds for after-hours trading that would generate returns,(5) The profits generated by the bank trading programs would be distributed to the Investors in the form of a return given the term "enhancement",(6) The profits generated by the bank trading programs would also be used for religious and humanitarian projects, (7) After one year, the Investors would receive their investment principal along with any accrued "enhancement", and (8) Tennison had invested $1,000,000 of his own money in The Joseph Project or a similar investment and had been receiving a 10% return monthly. Tennison's conduct is grounds to revoke his registration as a securities salesman with the Commission pursuant to A.R.S. §44-1962. Tennison's conduct is grounds to revoke his license as an investment adviser representative with the Commission pursuant to A.R.S. § 44-3201

Consent

Cease and Desist

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

$75,000.00

Revocation

Pursuant to A.R.S. § 44-1962, Tennison's securities salesman registration is revoked and pursuant to A.R.S. § 44-3201, Tennison's investment adviser representative license is revoked.

Claimants allege that from 2015 through early 2018 Tennison recommended investors invest in The Joseph Project, an alleged pooled investment vehicle and private placement offering that was not approved by Geneos. Claimants allege Tennison's recommendations were fraudulent and unsuitable.

$4,475,000.00

$495,000.00

Customer alleges that, in 2015 and 2016, Mr. Tennison recommended that the client invest in "The Joseph Project", which Customer did. Customer alleges that "The Joseph Project" was a Ponzi scheme. Customer seeks $1.3 million in damages, plus interest and attorneys' fees.

$1,300,000.00

$390,000.00

Customer alleges that Mr. Tennison recommended that he sell securities in which Customer was invested and invest in a private placement trust managed by Mr. Tennison. Customer alleges that Mr. Tennison's sell and purchase recommendations were fraudulent and unsuitable. Customer further alleges that Mr. Tennison engaged in selling away because the investment at issue was not approved by his broker dealer and that Mr. Tennison failed to disclose to Customer that he was strictly prohibited from recommending private placement investments without Geneos review and approval. As alleged by Customer, Mr. Tennison was terminated from Geneos as a result of misconduct relating to the investment at issue. Customer seeks damages in excess of $1.1 million.

$1,200,000.00

$400,000.00

FINRA

Without admitting or denying the findings, Tennison consented to the sanction and to the entry of findings that after initially cooperating with FINRA's investigation, he refused to appear and provide on-the-record testimony regarding allegations that Tennison recommended a $300,000 investment away from his member firm to a former firm customer.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All capacities

Indefinite

7/2/2018

Geneos Wealth Management Inc

Discharged

The firm received a written complaint from a former client of Mr. Tennison's expressing concerns about an investment she claims was recommended by Mr. Tennison in 2016. The firm has been unable to locate any record of said investment. Mr. Tennison has been minimally responsive to our requests for information. Mr. Tennison, does, however, assert that funds his former client wired to a 3rd party were not investment related.

Claimants allege that, in 2016, Mr. Tennison recommended that they invest in "The Joseph Project" resulting in complete loss of invested amount. Claimants seek damages, plus interest and attorney's fees.

$800,000.00

$195,000.00

CLIENT CLAIMS LIMITED PARTNERSHIP INVESTMENT REP MADE WAS UNSUITABLE

$28,013.52

$10,000.00

CLIENT MET DIRECTLY WITH THE PRINCIPALS OF IMH AT THEIR OFFICES IN SCOTTSDALE, AND THE CLIENT WAS A SENIOR COMMERCIAL LOAN OFFICER FOR A LOCAL FIRM AT THE TIME OF THE MEETING. HE HAD MANY YEARS EXPERIENCE IN THE LENDING BUSINESS. THE CLIENT EMAILED ME APPROX A WEEK AFTER MEETING WITH IMH AND INDICATED HE WANTED TO OPEN AN ACCOUNT FOR HIMSELF AND HIS MOTHER, JOINTLY. THEY WERE ACCREDITED INVESTORS. AFTER THE REAL ESTATE AND CREDIT MARKETS COLLAPSED, HE THEN DEMANDED HIS MONEY BACK. THE CLIENT MET AGAIN EARLIER THIS WEEK WITH SENIOR MANAGEMENT AT IMH IN SCOTTSDALE TO GET A FIRST HAND UPDATE.

OBERLIN FINANCIAL CORP.

Discharged

REP SUBMITTED TRANSACTION DOCUMENTS DIRECT TO PRODUCT SPONSOR COMPANY TO PURCHASE LOADED MUTUAL FUNDS WITH ANNUITY PROCEEDS WITHOUT PRIOR APPROVAL OF A SUPERVISING PRINCIPAL. PROCEDURES COMMUNICATED TO THE REP REQUIRES PRIOR APPROVAL ON ANNUITY SWITCHES.

ALLEGATIONS INCLUDE BREACH OF FIDUCIARY DUTY AND UNSUITABLILITY

$40,000.00

$79,380.00