Quarterly Securities Industry Newsletter: March 2026

Tuesday, March 24, 2026

Submitted by [user:fieldfirstname]

Annual Updating Amendment

It's time for state-licensed investment advisers to file the Annual Updating Amendment (AUA). Each year, the Division requires an AUA filing within 90 days after the end of the fiscal year. That date is March 31, 2026, for most firms. Even if there aren't changes to ADV Forms, investment advisers must refile the Form ADV Part 1A, 1B, 2A (Firm Brochure) and 2B (Brochure Supplement).

It's also recommended that you take the opportunity at that time to review your
Form U4 to confirm that it's current and accurate. You should also keep in mind
that the ADV Forms and your Form U4(s) are required to be kept materially
accurate throughout the year by filing an Other than Annual Updating Amendment or a Form U4 Amendment, as well as timely providing clients with any notice(s) of material changes to your Form ADV Part 2 that may be required.

If you have questions about the Annual Updating Amendment, contact the Division at 303-894-2320 or Dora_SecuritiesWebsite@state.co.us and ask to speak with a licensing examiner.

New NASAA IAR CE Course Catalog

The North American Securities Administrators Association (NASAA) launched a new public course catalog for investment adviser representative continuing education (IAR CE) courses.

​The new catalog allows users to filter course offerings by subject matter, course format, provider, level of complexity and whether a course has also been approved for continuing education credit for other professional designations.

Learn more about the new course catalog.

Sanctions Against Licensees

Mullins Investment Management, Inc.; Michael R. Mullins (CRD# 1574629)

• January 16, 2026: Colorado investment adviser and investment adviser representative stipulated to voluntary withdrawal of licenses and agree not to reapply. As part of a 2023 examination, staff alleged that respondents failed to comply with a 2021 Stipulation and Consent Order after not correcting deficiencies related to recordkeeping and billing practices. Additionally, respondents failed to retain a compliance consultant as required by the 2021 Order and failed to disclose the 2021 Order on an updated Form ADV.
  Marshall Financial Advisory, LLC; Richard David Marshall (CRD# 166011)

• January 12, 2026: Colorado investment adviser and investment adviser representative has conditions placed on licenses and are required to retain a compliance consultant approved by the Division for three years. As part of a 2025 examination, staff alleged that respondents failed to correct many of the deficiencies identified in a 2020 examination, after indicating they had corrected or will correct the deficiencies. Staff also identified additional deficiencies during the 2025 examination.

Other Enforcement Actions

Ann Vick

• March 13, 2026: On March 13, 2026, a Weld County jury found Ann Vick of northern Colorado guilty on eight counts of securities fraud following a five-day trial. Vick, restaurateur of several local establishments including Pinocchio’s and Delvickios, was originally indicted on January 25, 2024. Vick touted that she was a successful options trader and solicited investors to send her funds to invest. Vick would then issue promissory notes generally offering investors 5% to 10% returns each month (60% to 120% returns annually). She solicited approximately $3,000,000 from approximately 25 investors for her option trading/promissory note scheme. Vick’s sentencing is scheduled for May 21, 2026, at 9:00 a.m. The Colorado Division of Securities investigated this matter, and the Colorado Attorney General’s Criminal Justice/Financial Fraud Unit prosecuted the case.
  Market4Caster, LLC; Eric Gemelli

• February 10, 2026: In a stipulated agreement with the Colorado Securities Commissioner, Eric Gemelli and his company Market4Caster, LLC, of Golden, Colorado, admitted to unlicensed sales of millions of dollars of securities in violation of the Colorado Securities Act. Denver District Court Judge Christopher Jay Baumann accepted the stipulation and ordered Gemelli and Market4Caster, LLC, barred from any offering or sale of securities in Colorado or to any Colorado resident for 10 years. Both are also prohibited from acting as investment advisers or representatives in Colorado for 10 years.
  Visit the Division's Enforcement Action Table for additional information on these cases and others.

Have You Considered a Career as a State Securities Regulator?

The Division hires investigators, examiners, auditors (certified professional accountants), administrative support and supervisors. Our mission is to protect investors, and the work is challenging and rewarding. Visit our careers page to find current openings, learn more and apply. Interested candidates can email Dora_SecuritiesWebsite@state.co.us with questions.

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