FINRA

Respondent Caldwell 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.

Letter

Suspension

All capacities

Indefinite

Continues until required payment is made or discharged.

8/16/2024

Pursuant to Article VI, Section 3 of FINRA By-Laws, and FINRA Rule 9554, Respondent Caldwell is suspended on August 16, 2024 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.

Claimant alleges that Caldwell, while associated with CGMI, made an unsuitable recommendation and fraudulently induced Claimant to invest in a private investment not offered by CGMI resulting in monetary losses.

$500,000.00

Wire Fraud

FINRA

Without admitting or denying the findings, Caldwell consented to the sanction and to the entry of findings that she declined to provide on-the-record testimony requested by FINRA in connection with an investigation into the circumstances giving rise to Form U5s filed by her former member firms. The findings stated that one of Caldwell's former firms submitted an amended Form U5 disclosing that it was internally reviewing whether she had adequately disclosed OBAs and solicited firm clients to invest in her film production business. Shortly thereafter, the firm filed another amended Form U5 disclosing that its internal review had concluded that Caldwell did not adequately disclose her OBA and was soliciting firm clients to invest in her OBA, several of whom subsequently made investments. In addition, another firm filed a Form U5 disclosing that Caldwell had been discharged following an internal review concerning the accuracy of disclosures that she made to the firm and her compliance with its Outside Activities and Outside Investment Policy.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All capacities

Indefinite

7/6/2023

CLIENT ALLEGES FAILURE TO FOLLOW DIRECTIONS IN REGARDS TO A MANAGED ACCOUNT INVESTMENT. ACTIVITY DATES 1/8/07-7/27/09.

$7,875.49

CLIENT ALLEGES MISREPRESENTATION AND AN UNSUITABLE RECOMMENDATION RELATING TO THE LIQUIDITY OF AN AUCTION RATE SECURITIES PURCHASE. DAMAGES ARE UNSPECIFIED.

$150,000.00

CLIENT, THROUGH THEIR ATTORNEY ALLEGES AN UNSUITABLE RECOMMENDATION RELATING TO THE LIQUIDITY OF AN AUCTION RATE SECURITY. IN ADDITION, CLIENT ALLEGES AN UNAUTHORIZED TRANSACTION AND FAILURE TO FOLLOW INSTRUCTIONS. CLIENT HAS REQUESTED THE RETURN OF THEIR INVESTMENT.

$500,000.00

$300,000.00

HAMILTON INVESTMENTS INC.

Discharged

CUSTOMERS (PARENTS OF EX-FINANCE) CLAIM THAT THEIR ACCOUNTS WERE SHORT 250 RLAB AND HAD A DISCREPANCY IN THE MONEY IN THE CASH ACCOUNT.

VOLUNTARY TERMINATION: ON 3/92, A RESTRAINING ORDER WAS PLACED ON EX-FINANCE FOR ABUSIVE BEHAVIOR. HIS PARENTS THREATENED TO HARM ME PROFESSIONALLY BECAUSE OF THIS ACTION WHEN THEY FOUND OUT IN 10/92. THEY TOOK ACTION IN NOV. 1992 INVOLVING MY PREVIOUS EMPLOYER, CHATFIELD DEAN AND CURRENT EMPLOYER, HAMILTON INVESTMENTS. PRIOR TO 11/92 HIS PARENTS WERE AWARE OF THIS ERROR WHICH OCCURRED AT CHATFIELD WITH THE SHARES IN THE ACCOUNT. THE CUSTOMER'S WERE ALSO AWARE THAT I WAS TO TESTIFY V. CHATFIELD DEAN WITH THE SEC/DENVER, CO. IN NOVEMBER 1992 AND ANY COMPLAINT AGAINST ME AT THE TIME TO CHATFIELD WOULD REQUIRE FULL ACTION AGAINST ME IMMEDIATELY.