Brooklynn Chandler Willy of San Antonio, Texas, agreed to a one-year suspension of her license as an investment adviser representative with the Securities Commissioner and to pay back $2.75 million of commissions she received for the sale of alternative investments. The suspension and return of commissions is part of a disciplinary order that Texas Securities Commissioner, Travis J. Iles entered on October 16, 2020.
From March, 2014 through October, 2019 Willy worked as an investment adviser representative of Global Financial Private Capital, LLC (“GFPC”) and its successor J.W. Cole Advisors, Inc. and conducted investment advisory services under the d/b/a Texas Financial Advisory (“TFA”). In connection with her investment advisory services, Willy and other agents of TFA recommended that clients purchase certain alternative investments. Willy never disclosed to GFPC or J.W. Cole that she was engaging in the sale of alternative investments and was never registered as a dealer or agent of a dealer with the Securities Commissioner.
Willy did not conduct a reasonable level of due diligence to determine whether the alternative investments were suitable to clients prior to recommending they purchase the investments. In fact, in some instances, she recommended that conservative, unsophisticated investors allocate nearly half of their liquid assets in private, illiquid alternative investments.
In connection with these sales, Willy and the agents of TFA collected $2.75 million in commissions from the issuers of the alternative investments.
The Securities Commissioner has ordered Willy to comply with the terms of an undertaking wherein she agrees to pay back the $2.75 million in commissions to all clients to whom Willy and the agents of TFA sold the alternative investments.
The disciplinary order granted the registration of Queen B Advisors, LLC, an investment advisory firm owned by Willy. But both Willy and Queen B agreed to certain limitations on their registrations for a period of five years. Limitations include not having discretionary trading authority over any client accounts and a prohibition from recommending alternative investments. Queen B must also engage a compliance consultant to review its business activities once Willy has served the one-year suspension.