JD Advisors and John Davenport Consent Order

• * * * * * * * * * * * * * * * * * * * * * * * * * * IN THE MATTER OF: *

1. DAVENPORT ADVISORS, LLC * CRD NO. 327796 * CONSENT ORDER

JOHN F. DAVENPORT * MATTER NO. CO-25-202500-S CRD NO. 1448999 *

(“Respondents”) *

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1. PRELIMINARY STATEMENT WHEREAS, the Banking Commissioner (“Commissioner”) is charged with the administration of Chapter 672a of the General Statutes of Connecticut, the Connecticut Uniform Securities Act (“Act”), and Sections 36b-31-2 to 36b-31-33, inclusive, of the Regulations of Connecticut State Agencies (“Regulations”) promulgated under the Act; WHEREAS, J. Davenport Advisors, LLC (“JD Advisors”), located at 800 Connecticut Avenue, Suite E401, Norwalk, Connecticut 06854, was registered as an investment adviser under the Act from October 13, 2023, to December 31, 2025, at which time its registration expired due to its failure to renew its registration; WHEREAS, John F. Davenport (“Davenport”), the Chief Executive Officer and control person of JD Advisors, has been registered as an investment adviser agent under the Act with various firms and at various times from February 20, 2007, to December 31, 2025. Davenport was registered as an investment adviser agent of JD Advisors from October 13, 2023, to December 31, 2025, at which time his registration expired due to his failure to renew his registration;

WHEREAS, the Commissioner, through the Securities and Business Investments Division (“Division”) of the Department of Banking, conducted an examination of Respondents pursuant to Section 36b-14(d) of the Act and Section 36b-31-14f of the Regulations (“Examination”) and a related investigation pursuant to Section 36b-26(a) of the Act (“Investigation”) to determine whether Respondents violated, were violating or were about to violate provisions of the Act or Regulations or any order thereunder; WHEREAS, as a result of the Examination and Investigation, on January 14, 2026, the Commissioner, acting pursuant to Sections 36b-27 and 36b-15 of the Act, issued an Order to Cease and Desist, Notice of Intent to Fine, Notice of Intent to Revoke Registration as an Investment Adviser; Notice of Intent to Revoke Registration as an Investment Adviser Agent, and Notice of Right to Hearing against Respondents (Docket No. CDFR-25-202500-S) (collectively, “Notice”), which Notice is incorporated by reference herein; WHEREAS, on January 27, 2026, Respondents requested a hearing on the matters alleged in the Notice; WHEREAS, on February 26, 2026, the Commissioner issued a Notification of Hearing and Designation of Hearing Officer, wherein the Commissioner appointed Department of Banking Attorney Melissa Desmond as the Hearing Officer and scheduled a hearing on the matters alleged in the Notice for June 17, 2026 (“Hearing”); WHEREAS, Section 36b-27(f) of the Act provides, in relevant part, that “[a]ny time after the issuance of an order or notice provided for in subsection (a), (b) . . . or subdivision (1) of subsection (d) of this section, the commissioner may accept an agreement by any respondent named in such order or notice to enter into a written consent order in lieu of an adjudicative hearing”; WHEREAS, Section 36b-31(a) of the Act provides, in relevant part, that “[t]he commissioner may from time to time make . . . such . . . orders as are necessary to carry out the provisions of sections 36b-2 to 36b-34, inclusive”;

WHEREAS, Section 36b-31(b) of the Act provides, in relevant part, that “[n]o . . . order may be made . . . unless the commissioner finds that the action is necessary or appropriate in the public interest or for the protection of investors and consistent with the purposes fairly intended by the policy and provisions of sections 36b-2 to 36b-34, inclusive”; WHEREAS, an administrative proceeding initiated under Sections 36b-15 and 36b-27 of the Act would constitute a “contested case” within the meaning of Section 4-166(4) of the General Statutes of Connecticut; WHEREAS, Section 4-177(c) of the General Statutes of Connecticut and Section 36a-1-55(a) of the Regulations of Connecticut State Agencies provide that a contested case may be resolved by consent order, unless precluded by law; WHEREAS, Respondents and the Commissioner now desire to resolve the matters alleged in the Notice without the need for further administrative proceedings; WHEREAS, Respondents expressly consent to the Commissioner’s jurisdiction under the Act and to the terms of this Consent Order; WHEREAS, the Commissioner finds that the issuance of this Consent Order is necessary or appropriate in the public interest or for the protection of investors and consistent with the purposes fairly intended by the policy and provisions of the Act; WHEREAS, Respondents acknowledge that they have had the opportunity to consult with and be represented by independent counsel in negotiating and reviewing this Consent Order and that they execute this Consent Order freely; AND WHEREAS, Respondents, through their execution of this Consent Order, specifically assure the Commissioner that none of the violations alleged in the Notice or this Consent Order shall occur in the future.

1. CONSENT TO WAIVER OF PROCEDURAL RIGHTS
   WHEREAS, Respondents, through their execution of this Consent Order, voluntarily waive the following rights:

2. To be afforded notice and an opportunity for a hearing within the meaning of Sections
   36b-15(f) and 36b-27 of the Act and Section 4-177(a) of the General Statutes of Connecticut;

3. To present evidence and argument and to otherwise avail themselves of Sections 36b-15(f) and
   36b-27 of the Act and Section 4-177c(a) of the General Statutes of Connecticut; .

4. To present their position in a hearing in which each is represented by counsel;

5. To have a written record of the hearing made and a written decision issued by a hearing officer;

6. To seek judicial review of, or otherwise challenge or contest the matters described herein,
   including the validity of this Consent Order.

7. ACKNOWLEDGEMENT OF THE COMMISSIONER’S ALLEGATIONS
   WHEREAS, Respondents, through their execution of this Consent Order, acknowledge, without admitting or denying, the following allegations of the Commissioner:

8. JD Advisors violated Section 36b-31-14b of the Regulations by failing to maintain true, accurate
   and current books and records;

9. JD Advisors violated Section 36b-31-6f of the Regulations by failing to establish, enforce and
   maintain adequate supervisory procedures;

10. JD Advisors engaged in dishonest or unethical business practices within the meaning of Section
    36b-31-15c(8) of the Regulations by misrepresenting to clients the fee JD Advisors paid to its subadvisor for its services;

11. JD Advisors violated Section 36b-5(b)(1) of the Act and engaged in dishonest or unethical
    business practices within the meaning of 36b-31-15c(15) of the Regulations by failing to maintain a written investment advisory agreement/contract with a client;

12. JD Advisors violated Section 36b-14(d) of the Act and Section 36b-31-14f of the Regulations by
    failing to provide copies of and make required books and records available to the Division during the Examination;

13. Davenport violated Section 36b-14(c) of the Act and 36b-31-14e of the Regulations by failing to
    file correcting amendments to his Form U4; and,

14. Davenport violated Section 36b-23 of the Act by making a false or misleading statement to the
    Commissioner. WHEREAS, the Commissioner would have the authority to enter findings of fact and conclusions of law after granting Respondents an opportunity for a hearing; AND WHEREAS, Respondents acknowledge the possible consequences of an administrative hearing and voluntarily agrees to consent to the entry of the sanctions described below;

15. CONSENT TO ENTRY OF SANCTIONS
    WHEREAS, Respondents, through their execution of this Consent Order, consent to the Commissioner’s entry of an order imposing on them the following sanctions:

16. JD Advisors, its officers, representatives, agents, and employees shall cease and desist from
    engaging in conduct constituting or which would constitute a violation of the Act or any regulation, rule or order adopted or issued under the Act, either directly or through any person, organization or other device, including without limitation, violations of Sections 36b-5(b)(1) and 36b-14(d) of the Act and Sections 36b-31-14b, 36b-31-6f, 36b-31-14f of the Regulations; and from engaging in dishonest or unethical business practices within the meaning of Sections 36b- 31-15c(8) and 36b-31-15c(15) of the Regulations;

17. Davenport shall cease and desist from engaging in conduct constituting or which would constitute
    a violation of the Act or any regulation, rule or order adopted or issued under the Act, either directly or through any person, organization or other device, including without limitation, violation of Section 36b-31-14e of the Regulations and Section 36b-23 of the Act;

18. Effective upon the entry of this Consent Order by the Commissioner, the registration of J.
    Davenport Advisors, LLC as an investment adviser shall be REVOKED; and,

19. Effective upon the entry of this Consent Order by the Commissioner, the registration of John F.
    Davenport as an investment adviser agent shall be REVOKED, and continuing for a period of seven years thereafter, he shall be BARRED from directly or indirectly, through any person, organization, entity or other device, (i) transacting business in or from Connecticut as a broker- dealer, agent, investment adviser or investment adviser agent, as such terms are defined in the Act and notwithstanding any definitional exclusion that might otherwise be available under the Act; and (ii) acting in any other capacity which requires a license or registration from the Commissioner.

20. CONSENT ORDER
    NOW THEREFORE, the Commissioner enters the following:

21. The Sanctions set forth above be and are hereby entered;

22. Entry of this Consent Order by the Commissioner is without prejudice to the right of the
    Commissioner to take enforcement action against Respondents based upon a violation of this Consent Order or the matters underlying its entry if the Commissioner determines that compliance with the terms herein is not being observed;

23. Nothing in this Consent Order shall be construed as limiting the Commissioner’s ability to take
    enforcement action against Respondents and/or their affiliates and successors in interest based upon evidence of which the Division was unaware on the date hereof relating to a violation of the Act or any regulation or order under the Act;

24. Respondents shall not take any action or make or permit to be made any public statement,
    including in regulatory filings, any proceeding in any forum or otherwise, denying, directly or indirectly, any allegation referenced in this Consent Order or create the impression that this Consent Order is without factual basis;

25. Respondents shall not take any position in any proceeding brought by or on behalf of the
    Commissioner, or to which the Commissioner is a party, that is inconsistent with any part of this Consent Order. Nothing in this Consent Order affects Respondents’ (i) testimonial obligations; or (ii) right to take a legal or factual position in litigation or other legal proceeding in which the Commissioner is not a party; and

26. This Consent Order shall become final when entered.
    So ordered at Hartford, Connecticut, this 18 day of March 2026. ___/s/______________ th Jorge L. Perez Banking Commissioner

CONSENT TO ENTRY OF ORDER I, John F. Davenport, state on behalf of J. Davenport Advisors, LLC, Inc. (“JD Advisors”), that I have read the foregoing Consent Order; that I know and fully understand its contents; that I am authorized to execute this Consent Order on behalf of JD Advisors; that JD Advisors agrees freely and without threat or coercion of any kind to comply with the terms and conditions stated herein; and that JD Advisors consents to the entry of this Consent Order.

1. Davenport Advisors, LLC By: ___/s/____________________ John F. Davenport Chief Executive Officer State of: Connecticut County of: Fairfield On this the 17 day of March 2026, before me, the undersigned officer, personally appeared John F. Davenport, who acknowledged himself to be the Chief Executive Officer of J. Davenport Advisors, LLC, and that he, as such Chief Executive Officer, being authorized so to do, executed the foregoing instrument for the purposes therein contained, by signing the name of the limited liability company by himself as Chief Executive Officer. In witness whereof I hereunto set my hand. ____/s/______________________________ _ Notary Public Date Commission Expires: Apr 30, 2030

CONSENT TO ENTRY OF ORDER I, John F. Davenport, state that I have read the foregoing Consent Order; that I know and fully understand its contents; that I agree freely and without threat or coercion of any kind to comply with the terms and conditions stated herein; and that I consent to the entry of this Consent Order. ___/s/_____________________________ John F. Davenport State of: Connecticut County of: Fairfield On this the 17 day of March 2026, before me, the undersigned officer, personally appeared, John F. Davenport, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purposes therein contained. In witness whereof I hereunto set my hand. ____/s/_____________________________ Notary Public Date Commission Expires: Apr 30, 2030