GEORGIA

THE COMMISSIONER OF SECURITIES FOR THE STATE OF GEORGIA ("COMMISSIONER") ENTERED AN ORDER ON SEPTEMBER 13, 2013: (I) SUMMARILY SUSPENDING THE REGISTRATIONS OF BRIDGE SECURITIES, LLC (CRD# 156724) AND PAUL JAMES MARSHALL (CRD# 1889692) ("RESPONDENTS"); AND (II) REVOKING SUCH REGISTRATIONS PENDING A 30-DAY EFFECTIVENESS PERIOD DURING WHICH RESPONDENTS MAY SEEK A HEARING. THE ORDER WAS BASED ON THE ENTRY OF A PRELIMINARY INJUNCTION BY THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA, ATLANTA DIVISION AGAINST RESPONDENTS AND THAT COURT'S ORDERING OF AN ASSET FREEZE OF RESPONDENTS' FUNDS, ALL IN CONNECTION WITH THE FILING OF A COMPLAINT BY THE UNITED STATES SECURITIES AND EXCHANGE COMMISSION ("SEC") AGAINST RESPONDENTS ALLEGING SEVERAL COUNTS OF SECURITIES FRAUD UNDER FEDERAL LAW (SEC V. PAUL MARSHALL ET AL., NO. 1:13-CV-3032-TCB (N.D. GA. SEPTEMBER 11,2013).

Order

Revocation

UNITED STATES SECURITIES AND EXCHANGE COMMISSION

SEC LITIGATION RELEASE 22797, SEPTEMBER 12, 2013: ON SEPTEMBER 11, 2013, THE SECURITIES AND EXCHANGE COMMISSION FILED AN EMERGENCY ACTION SEEKING A TEMPORARY RESTRAINING ORDER AND OTHER EMERGENCY RELIEF IN FEDERAL COURT IN THE NORTHERN DISTRICT OF GEORGIA, CHARGING PAUL MARSHALL (MARSHALL), A STATE-REGISTERED INVESTMENT ADVISER REPRESENTATIVE, AND THREE ATLANTA-BASED COMPANIES THAT HE OWNED AND CONTROLLED WITH VIOLATIONS OF THE FEDERAL SECURITIES LAWS FOR MISAPPROPRIATING CLIENT FUNDS. ACCORDING TO THE COMMISSION'S COMPLAINT, SINCE AT LEAST 2011, MARSHALL, AN INVESTMENT ADVISER REPRESENTATIVE OF THE ONE OF THE COMPANIES, MISAPPROPRIATED AT LEAST $2 MILLION FROM ADVISORY CLIENTS. IN ITS COMPLAINT, THE COMMISSION ALLEGES THAT MARSHALL INSTRUCTED CLIENTS, SOME OF WHOM WERE ELDERLY, TO TRANSFER FUNDS TO BANK ACCOUNTS UNDER HIS CONTROL FOR PURPORTED INVESTMENT IN VARIOUS SECURITIES, INCLUDING MUTUAL FUNDS. INSTEAD, MARSHALL USED THOSE CLIENT FUNDS TO PAY PERSONAL EXPENSES, INCLUDING LUXURY VACATIONS AND PRIVATE SCHOOL TUITION FOR HIS CHILDREN. THE COMPLAINT FURTHER ALLEGES THAT MARSHALL CONCEALED HIS FRAUD BY PROVIDING ADVISORY CLIENTS WITH FABRICATED ACCOUNT STATEMENTS. ADDITIONALLY, THE COMMISSION'S COMPLAINT ALLEGES THAT MARSHALL, CURRENTLY THE MAJORITY OWNER AND MANAGING DIRECTOR OF A PURPORTED ALTERNATIVE FUEL COMPANY, MISAPPROPRIATED $100,000 FROM AN ADVISORY CLIENT WHO INVESTED IN THAT COMPANY. THE COMMISSION'S COMPLAINT ALLEGES THAT, THROUGH THEIR MISCONDUCT, MARSHALL, AND THE COMPANIES, VIOLATED SECTION 10(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 10B-5 THEREUNDER, AND THAT MARSHALL AND THE PURPORTED ALTERNATIVE FUEL ENTITY, VIOLATED SECTION 17(A) OF THE SECURITIES ACT OF 1933. FINALLY, THE COMPLAINT ALLEGES THAT MARSHALL AND TWO OF THE ENTITIES VIOLATED SECTIONS 206(1) AND 206(2) OF THE INVESTMENT ADVISERS ACT OF 1940. ON SEPTEMBER 11, 2013, THE UNITED STATES DISTRICT JUDGE FOR THE NORTHERN DISTRICT OF GEORGIA, GRANTED THE COMMISSION'S REQUEST FOR EMERGENCY RELIEF, ISSUING AN ORDER TEMPORARILY RESTRAINING MARSHALL, AND THE ENTITIES FROM FURTHER SECURITIES LAWS VIOLATIONS, FREEZING THEIR ASSETS, PREVENTING THE DESTRUCTION OF DOCUMENTS, REQUIRING AN ACCOUNTING, AND EXPEDITING DISCOVERY. THE COURT ALSO SET A HEARING DATE OF SEPTEMBER 20, 2013 FOR THE COMMISSION'S REQUEST FOR A PRELIMINARY INJUNCTION. THE COMMISSION'S COMPLAINT ALSO SEEKS A PERMANENT INJUNCTION, DISGORGEMENT OF ILL-GOTTEN GAINS WITH PREJUDGMENT INTEREST, AND CIVIL PENALTIES. THOSE CLAIMS WILL BE ADJUDICATED AT A LATER DATE.

Judgment Rendered

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

Disgorgement

$1,535,981.41

Monetary Penalty other than Fines

Injunction

FINRA

FINRA RULES 2010, 8210, NASD RULES 2110, 2330: MARSHALL CONVERTED FUNDS TOTALING $25,000 FROM HIS MEMBER FIRM'S CUSTOMER. MARSHALL DEPOSITED CHECKS FOR THE CUSTOMER, A TOTAL OF $25,000, INTO A BANK ACCOUNT HE CONTROLLED, FAILED TO INVEST THE FUNDS IN A REAL ESTATE ENTITY ON THE CUSTOMER'S BEHALF, AND INSTEAD CONVERTED THE FUNDS TO HIS OWN USE AND BENEFIT. THE CUSTOMER PROVIDED SOME CHECKS TO MARSHALL, ONE MADE PAYABLE TO MARSHALL AND ANOTHER TO AN ENTITY FOR WHICH MARSHALL SERVED AS PRESIDENT AND DIRECTOR. THE CHECKS WERE PROVIDED TO MARSHALL BY THE CUSTOMER FOR PURPOSES OF INVESTMENT IN A REAL ESTATE ENTITY. MARSHALL HAD SOLICITED THE CUSTOMER TO INVEST IN THE ENTITY AND PROVIDED HER WITH A WRITTEN CONTRACT, WHICH SHE SIGNED, TO INVEST $30,000 IN EARNEST MONEY FOR THE REAL ESTATE PROJECT. TO DATE, MARSHALL HAS FAILED TO RETURN ANY OF THE FUNDS TO THE CUSTOMER. WHILE HE WAS ASSOCIATED WITH ANOTHER MEMBER FIRM, MARSHALL PROVIDED A BUSINESS CARD TO A CUSTOMER THAT REFLECTED FALSE AND MISLEADING INFORMATION. SPECIFICALLY, THE BUSINESS CARD REFLECTED THAT MARSHALL WAS A MANAGING DIRECTOR OF A CERTAIN DIVISION OF A COMPANY. AT NO TIME WAS MARSHALL ASSOCIATED WITH OR EMPLOYED BY THE COMPANY, NOR DID HE RECEIVE APPROVAL TO USE THE CARD FROM HIS FIRM. MARSHALL FAILED TO FULLY RESPOND TO FINRA REQUESTS FOR INFORMATION AND DOCUMENTS. THE REQUESTED DOCUMENTS WERE MATERIAL TO FINRA'S INVESTIGATION, AND MARSHALL'S FAILURE TO PRODUCE THEM IMPEDED FINRA'S ABILITY TO CONDUCT THE INVESTIGATION.

Decision & Order of Offer of Settlement

Bar (Permanent)

All Capacities

9/12/2013

WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, PAUL JAMES MARSHALL CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE HE IS BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY. AS ALLEGED IN THE COMPLAINT (AS AMENDED HEREIN), PAUL JAMES MARSHALL FAILED TO FULLY RESPOND OR TIMELY RESPOND, TO FINRA'S MULTIPLE REQUESTS FOR DOCUMENTS, INCLUDING TAX RETURNS AND COPIES OF STATEMENTS FOR BANK ACCOUNTS HE CONTROLLED, IN VIOLATION OF FINRA RULES 8210 AND 2010.

FINRA

RESPONDENT MARSHALL FAILED TO COMPLY WITH AN ARBITRATION AWARD OR SETTLEMENT AGREEMENT OR TO SATISFACTORILY RESPOND TO A FINRA REQUEST TO PROVIDE INFORMATION CONCERNING THE STATUS OF COMPLIANCE. (THE HEARING PANEL'S RESTITUTION ORDER)

LETTER

Suspension

ANY CAPACITY

N/A

11/16/2012

PURSUANT TO ARTICLE VI, SECTION 3 OF FINRA BY-LAWS, AND FINRA RULE 9554, RESPONDENT MARSHALL IS SUSPENDED NOVEMBER 16, 2012 FOR FAILURE TO COMPLY WITH AN ARBITRATION AWARD OR SETTLEMENT AGREEMENT OR TO SATISFACTORILY RESPOND TO A FINRA REQUEST TO PROVIDE INFORMATION CONCERNING THE STATUS OF COMPLIANCE. (THE HEARING PANEL'S RESTITUTION ORDER) - ALTHOUGH MARSHALL INITIALLY APPEALED THIS DECISION TO THE FINRA NATIONAL ADJUDICATORY COUNCIL (NAC), HE SUBSEQUENTLY REQUESTED THAT THE APPEAL BE WITHDRAWN. ON MAY 16, 2012, THE FINRA OFFICE OF GENERAL COUNSEL ACKNOWLEDGED HIS REQUEST AND ADVISED HIM THAT THE NAC DETERMINED NOT TO CALL THIS MATTER FOR REVIEW. AS A RESULT, THE DECISION ISSUED BY THE OFFICE OF HEARING OFFICERS ON JANUARY 25, 2012, INCLUDING THE SANCTIONS IMPOSED BY THE DECISION, BECAME FINAL UPON HIS WITHDRAWAL REQUEST.

FINRA

FINRA RULES 2010, 8210, NASD RULES 2110, 2330(A), 2370 - PAUL JAMES MARSHALL OBTAINED THE OPTION TO PURCHASE SHARES OF A COMPANY AFTER HE OBTAINED BANK FINANCING FOR THE COMPANY AND OFFERED TO PURCHASE SHARES FOR A MEMBER FIRM CUSTOMER. THE CUSTOMER WIRED $38,200 TO A BANK ACCOUNT CONTROLLED BY MARSHALL TO PURCHASE THE SHARES BUT MARSHALL FAILED TO EXERCISE THE OPTION, DID NOT FORWARD THE FUNDS TO THE COMPANY AND DID NOT RETURN THE MONEY TO THE CUSTOMER BECAUSE MARSHALL MADE THE UNILATERAL DECISION THAT A JOINT BUSINESS VENTURE BETWEEN HIMSELF AND THE CUSTOMER OWED HIM THE MONEY. MARSHALL USED THE MONEY FOR HIS PERSONAL EXPENSES AND NOT FOR THE CUSTOMER'S BENEFIT. MARSHALL BORROWED $25,000 FROM THE CUSTOMER CONTRARY TO HIS FIRM'S WRITTEN SUPERVISORY PROCEDURES THAT DID NOT PERMIT REGISTERED REPRESENTATIVES FROM BORROWING FROM CUSTOMERS. MARSHALL WROTE A CHECK PAYABLE TO THE CUSTOMER'S BUSINESS FOR $25,000 TO PAY BACK THE LOAN BUT IT WAS NOT HONORED DUE TO MARSHALL'S LACK OF FUNDS IN HIS BANK ACCOUNT. MARSHALL FAILED TO COMPLETELY RESPOND TO FINRA REQUESTS FOR INFORMATION.

Decision

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

$3,500.00

Monetary Penalty other than Fines

$2,739.15

Suspension

ANY CAPACITY

30 BUSINESS DAYS

6/4/2012

7/16/2012

HEARING PANEL DECISION RENDERED JANUARY 25, 2012 WHEREIN MARSHALL IS FINED $3,500, SUSPENDED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY FOR 30 BUSINESS DAYS, ORDERED TO PAY $25,000, PLUS INTEREST, IN RESTITUTION TO A CUSTOMER, AND ORDERED TO PAY COSTS OF $2,739.15. MARSHALL WAS FOUND NOT LIABLE FOR MISAPPROPRIATING CUSTOMER FUNDS IN VIOLATION OF NASD RULES 2110 AND 2330(A). THE FINE AND COSTS SHALL BE DUE AND PAYABLE UPON MARSHALL'S RETURN TO THE SECURITIES INDUSTRY. APPEALED TO THE NAC ON FEBRUARY 15, 2012. APPEAL WITHDRAWN MAY 9, 2012. DECISION IS FINAL MAY 9, 2012. SUSPENSION IS EFFECTIVE JUNE 4, 2012 THROUGH JULY 16, 2012.

GEORGIA STATE SECURITIES DIVISION

EFFECTED PRIVATE SECURITIES TRANSACTION AND SUPPOSELY TOLD CLIENT TO SALE STOCK FOR MARGIN CALL

Consent

Cease and Desist/Injunction

HEIGHTEN SUPERVISION INDEPENDENT COMPLIANCE CONSULTANT

MR.MARSHALL NEITHER ADMITS OR DENIES THESE FINDINGS FACT AND CONCLUSIONS OF LAW

NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Consent

Monetary/Fine

$2,500.00

Censure

Not Provided