UNITED STATES SECURITIES AND EXCHANGE COMMISSION

SEC ADMIN RELEASE 34-73186, INVESTMENT ADVISERS ACT RELEASE 40-3931 / SEPTEMBER 23, 2014: 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 BLAKE RICHARDS ("RESPONDENT" OR "RICHARDS"). AFTER AN INVESTIGATION, THE DIVISION OF ENFORCEMENT ALLEGES THAT: ON AUGUST 26, 2014, A FINAL JUDGMENT WAS ENTERED AGAINST RICHARDS. THE FINAL JUDGMENT INCORPORATED AN EARLIER ORDER OF AUGUST 20, 2013, WHICH BY CONSENT PERMANENTLY ENJOINED RICHARDS FROM FUTURE VIOLATIONS OF SECTIONS 17(A) OF THE SECURITIES ACT OF 1933, SECTION 10(B) OF THE EXCHANGE ACT AND RULE 10B-5 THEREUNDER, AND SECTIONS 206(1) AND 206(2) OF THE ADVISERS ACT, IN THE CIVIL ACTION NUMBER 1:13-CV-1729, IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA.

Order

Bar (Permanent)

SEE COMMENT

11/14/2014

FINRA

RESPONDENT RICHARDS FAILED TO RESPOND TO FINRA REQUEST FOR INFORMATION.

LETTER

Bar (Permanent)

All Capacities

Indefinite

9/23/2013

PURSUANT TO FINRA RULE 9552(H) AND IN ACCORDANCE WITH FINRA'S NOTICE OF SUSPENSION AND SUSPENSION FROM ASSOCIATION LETTERS DATED JUNE 20, 2013 AND JULY 15, 2013, RESPECTIVELY, ON SEPTEMBER 23, 2013, RICHARDS IS BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY. RESPONDENT FAILED TO REQUEST TERMINATION OF HIS SUSPENSION WITHIN THREE MONTHS OF THE DATE OF THE NOTICE OF SUSPENSION; THEREFORE, HE IS AUTOMATICALLY BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY.

UNITED STATES SECURITIES AND EXCHANGE COMMISSION

SEC LITIGATION RELEASE 22706, MAY 23, 2013: THE SECURITIES AND EXCHANGE COMMISSION FILED AN EMERGENCY ACTION SEEKING A TEMPORARY RESTRAINING ORDER AND OTHER EMERGENCY RELIEF CHARGING BLAKE RICHARDS (RICHARDS), WITH VIOLATIONS OF THE FEDERAL SECURITIES LAWS FOR MISAPPROPRIATING INVESTOR FUNDS. THE COMPLAINT ALLEGES THAT RICHARDS VIOLATED THE ANTIFRAUD PROVISIONS OF THE FEDERAL SECURITIES LAWS, SECTION 17(A) OF THE SECURITIES ACT OF 1933, SECTION 10(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 10B-5. THE COMPLAINT ALSO ALLEGES THAT RICHARDS VIOLATED SECTIONS 206 (1) AND SECTION 206 (2) OF THE INVESTMENT ADVISERS ACT OF 1940, THE ANTIFRAUD PROVISIONS OF THE ADVISERS ACT. THE HONORABLE CHIEF JUDGE OF THE NORTHERN DISTRICT OF GEORGIA, GRANTED THE COMMISSION'S REQUEST FOR EMERGENCY RELIEF, ISSUING AN ORDER THAT TEMPORARILY RESTRAINED RICHARDS FROM FURTHER SECURITIES LAWS VIOLATIONS, FROZE RICHARDS'S ASSETS, PREVENTED THE DESTRUCTION OF DOCUMENTS AND EXPEDITED DISCOVERY. THE COURT ALSO SET A HEARING DATE OF JUNE 6 FOR THE COMMISSION'S REQUEST FOR A PRELIMINARY INJUNCTION. THE COMMISSION'S COMPLAINT ALLEGES THAT, SINCE AT LEAST 2008, RICHARDS, A REGISTERED REPRESENTATIVE OF A BROKER DEALER, MISAPPROPRIATED AT LEAST $2 MILLION FROM AT LEAST SEVEN INVESTORS. THE MAJORITY OF THE MISAPPROPRIATED FUNDS CONSTITUTED RETIREMENT SAVINGS AND/OR LIFE INSURANCE PROCEEDS FROM DECEASED SPOUSES. IN ITS COMPLAINT, THE COMMISSION ALLEGES THAT RICHARDS INSTRUCTED INVESTORS TO WRITE OUT CHECKS TO ENTITIES UNDER HIS CONTROL WITH THE UNDERSTANDING THAT RICHARDS WOULD INVEST THEIR FUNDS IN FIXED INCOME ASSETS, VARIABLE ANNUITIES AND/OR COMMON STOCK. THE COMPLAINT ALLEGES THAT NONE OF THESE INVESTMENTS WERE EVER MADE. NONE OF THE INVESTMENTS APPEARED ON THE CLIENT'S BROKERAGE ACCOUNT STATEMENTS, AND RICHARDS RECEIVED NO COMMISSION INCOME FROM THESE INVESTMENTS. THE COMPLAINT FURTHER ALLEGES THAT RICHARDS SIPHONED OFF THE FUNDS ENTRUSTED TO HIM FOR PERSONAL USE.

Judgment Rendered

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

Disgorgement

$1,829,923.21

Injunction