Initiated By
Connecticut
Allegations
On May 29, 2020, the Banking Commissioner entered a Consent Order (No. CO-20-8460-S) with respect to Glenn Bradford Johnson of Niantic, Connecticut, Annmarie Lucy Savona of Waterford, Connecticut and Jabez Financial, LLC, a Connecticut-registered investment adviser located at 251 West Main Street, Niantic, Connecticut 06357. Johnson is the president and control person of Jabez Financial, LLC, a single member limited liability company. The Consent Order alleged that from approximately August 2016 to November 2017, Johnson and Savona sold $2.65 million of unregistered interests in various investment funds offered by Woodbridge Group of Companies, LLC d/b/a Woodbridge Wealth to approximately 22 Connecticut residents and two Massachusetts residents. Woodbridge Group of Companies, LLC, based in California, was a defendant in a civil action brought by the Securities and Exchange Commission alleging that it operated a purported Ponzi scheme. For their role in selling interests in the Woodbridge Funds, Johnson and Savona received $123,082.43 in commissions and reimbursement of costs from Woodbridge Group of Companies, LLC. The Consent Order alleged that Johnson and Savona violated Section 36b-16 of the Connecticut Uniform Securities Act by selling unregistered securities and that they transacted business as unregistered agents of issuer in contravention of Section 36b-6(a) of the Act.
Resolution
Consent
Sanctions
Cease and Desist
Sanctions
Civil and Administrative Penalty(ies)/Fine(s)
Amount
$30,000.00
Sanctions
Disgorgement
Amount
$123,082.43
Sanctions
The Consent Order directed Johnson and Savona to cease and desist from regulatory violations and to jointly and severally disgorge the $123,082.43 in commissions they earned to affected investors. The disgorgement fund would be established through outside legal counsel, with $30,000 funded outright and the balance contributed in four equal installments of $23,270.60, the last being remitted on or before September 21, 2020. While the Consent Order contemplated that Johnson and Savona would jointly and severally liable for a $30,000 administrative fine, collection of that fine would be stayed for three years subject to Johnson and Savona providing updated financial documentation demonstrating their continuing inability to pay the fine. After three years, payment of the fine would be permanently waived.
In addition, the Consent Order limited the investment advisory activities that Johnson and Jabez Financial, LLC could perform. More specifically, 1) for 2 years Johnson and Jabez Financial, LLC would be prohibited from exercising discretionary trading authority with respect to client accounts and from maintaining custody or control of client funds or securities; and 2) for three years, Johnson and Jabez Financial, LLC would be required to limit their investment advisory activity to limited securities, investment company securities, commercial paper, certificates of deposit, corporate debt securities, United States and municipal securities and insurance products subject to regulation by the Connecticut Insurance Commissioner.