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 Erin Verespy ("Respondent"). The Commission finds that on April 14, 2021, Verespy pled guilty to one count of conspiracy to commit wire fraud and bank fraud in violation of Title 18 United States Code, Section 1349 before the United States District Court for the Southern District of New York, in United States v. Erin Verespy, 7:21- CR-00024(CS). On March 29, 2022, a judgment in the criminal case was entered against Verespy. She was sentenced to a prison term of 66 months followed by five years of supervised release and ordered to make restitution in the amount of $16,053,508.19, jointly and severally with three codefendants, and to forfeit $1,066,038.02. The July 13, 2020 Sealed Complaint, and the March 10, 2021 Superseding Information to which Verespy pled guilty, alleged, inter alia, that Verespy served as Chief Financial Officer of Employee Benefit Solutions LLC ("EBS") from at least July 2017 and continuing through 2019, that EBS served as a third-party administrator to process healthcare claims for an automobile dealership chain, that EBS would generate bimonthly invoices for the automobile dealership chain reflecting expenses submitted to EBS by healthcare providers for the dealership chain's employees, that the automobile dealership chain would reimburse EBS by wire transfer the total invoiced, that EBS did not pay the billing healthcare providers for a large number of the claims for which the automobile dealership chain provided reimbursement, and that some of the funds were instead used to pay personal expenses of Verespy's co-defendants and were otherwise misappropriated.

Order

Bar (Permanent)

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

Indefinite

6/17/2022

Participating in any offering of a penny stock

Indefinite

6/17/2022

Connecticut

On June 25, 2020, the Banking Commissioner issued an Order to Cease and Desist, Notice of Intent to Fine, Notice of Intent to Revoke Registrations as a Broker-dealer Agent and an Investment Adviser Agent and Notice of Right to Hearing (Docket No. NRCDF-20-8507-S) against Erin Lynn Verespy of Trumbull, Connecticut. Respondent Verespy was previously registered as a broker-dealer agent and investment adviser agent of HD Vest Investment Services and HD Vest Advisory Services, Inc., respectively, until June 2019 when filings to withdraw her registrations in all jurisdictions became effective. Connecticut law permits the Commissioner to initiate revocation proceedings within one year after a withdrawal becomes effective. The action alleged that respondent Verespy 1) engaged in dishonest or unethical business practices by faiing to provide HD Vest with written notice of outside business activity in which she was engaged; 2) violated Section 36b-31-14e of the Regulations under the Connecticut Uniform Securities Act by failing to amend her regulatory filings to disclose pending civil litigation involving a Connecticut client; and 3) enaged in dishonest or unethical business practices by borrowing money from a customer without the customer's prior consent and without notice to her employing firm. The action acknowledged that, following the initiation of litigation, respondent Verespy agreed to pay back $800,000 to the affected Connecticut customer.

Consent

Bar (Temporary/Time Limited)

Broker-dealer, broker-dealer agent, investment adviser, investment adviser agent

10 years

5/2/2022

5/2/2032

Cease and Desist

Revocation

Resolved without hearing via May 2, 2022 Consent Order. The Consent Order noted that Verespy had provided a written financial affidavit to the Commissioner demonstrating that she was unable to pay any fine that might otherwise have been imposed in the administrative proceeding or as a term of the Consent Order. The Consent Order revoked Verespy's registrations as a broker-dealer agent and an investment adviser agent; rendered the June 25, 2020 Order to Cease and Desist permanent; and barred Verespy for ten years from 1) transacting business as an agent, broker-dealer, broker-dealer agent, investment adviser or investment adviser agent; 2) maintaining a direct or indirect ownership interest in a Connecticut registered broker-dealer or investment adviser; and 3) acting in any other cpaacity requiring a license or registration under laws admnistered by the Commissioner. The Consent Order also stayed imposition of a $20,000 fine for three years, following which the fine would be waived if Verespy remained unable to pay the amount assessed.

FINRA

Without admitting or denying the findings, Verespy consented to the sanction and to the entry of findings that she refused to appear for on-the-record testimony requested by FINRA after her member firm amended her Form U4 to reflect that she had been named as a defendant in an investment-related, consumer-initiated civil litigation in which it was alleged that she misused and misappropriated the claimants' funds in her capacity as bookkeeper and financial advisor.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All capacities

Indefinite

4/15/2019

Claimants alleged the representative misused and misappropriated claimants' funds in her capacity as bookkeeper and financial advisor.

$600,000.00

$1,000,000.00