Rhode Island Securities Division Consent Agreement with Strategic Financial LLC

Detected March 17th, 2026

Summary

The Rhode Island Securities Division has entered into a consent agreement with Strategic Financial LLC for violations of the Rhode Island Uniform Securities Act. The firm will pay a $3,000 penalty for conducting business without proper registration as an investment adviser in the state.

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What changed

The Rhode Island Securities Division has issued a Consent Agreement with Strategic Financial LLC (Respondent) resolving alleged violations of R.I. Gen. Laws §§ 7-11-203 and 7-11-204(1)(ii). The investigation revealed that beginning in 2018, the Respondent conducted business in Rhode Island exceeding the de minimis exemption threshold with more than five clients within a twelve-month period, while not being registered as an investment adviser in the state. Additionally, an associated investment adviser representative engaged in advisory business without proper Rhode Island registration.

As a result of these violations, Strategic Financial LLC has agreed to pay a penalty of $3,000 to the Department. The firm has also taken steps to ensure full compliance with R.I. Gen. Laws § 7-11-203. Regulated entities operating in Rhode Island should ensure they are properly registered as investment advisers if they exceed the de minimis exemption thresholds and that all associated representatives are also appropriately licensed.

What to do next

Review registration status for all states where advisory business is conducted.
Ensure all investment adviser representatives are properly registered in each state of operation.
Verify compliance with de minimis exemption thresholds and state-specific registration requirements.

Penalties

A penalty of Three Thousand Dollars ($3,000.00) to the Department.

Source document (simplified)

STATE OF RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION, DIVISION OF SECURITIES 1511 PONTIAC AVENUE, BUILDING 69-1 CRANSTON, RI 02920 IN THE MATTER OF STRATEGIC FINANCIAL LLC RESPONDENT :CONSENT AGREEMENT : 2025-SC-003 The Securities Division (the "Division") of the Rhode Island Department of Business Regulation (the "Department") enters into this Consent Agreement ("Agreement") to resolve concerns that R.I. Gen. Laws §§ 7-11-203 and 7-11-204(1 )(ii) of the Rhode Island Uniform Securities Act of 1990 (the "RIUSA" or the "Act"), R.I. Gen. Laws§ 7-11-101 et seq. of the Rhode Island General Laws, may have been violated by Strategic Financial, LLC ("Respondent"). The Division and the Respondent have determined to resolve this matter, after investigation, but without instituting formal proceedings, by entering into this Consent Agreement. 11. It is hereby agreed by and between the Division and Strategic Financial, LLC that: 1. Respondent is a limited liability company organized under the laws of the State of Connecticut, has a principal place of business at 1695 Ellington Road, Suite 202, South Windsor, CT 06074. 2. Respondent is registered as an Investment Adviser Firm since November 14, as CRD #122437. 3. At all ti mes relevant to this Agreement, it has been unlawful to transact

business in this State as an investment adviser or investment adviser representative unless licensed or exempt from licensing under R.I. Gen. Laws § 7-11-203 . 4. On April 28, 2025, during the Respondent's initial registration examination by the Division the Division discovered that: a.) Beginning in 2018, Respondent had conducted business and exceeded the de minimis exemption threshold by having more than five (5) Rhode Island clients within a twelve-month period while not being registered as an investment adviser in Rhode Island. This constitutes a violation of R.I. Gen. Laws § 7-11-204(1 ){ii). b.) An investment adviser representative associated with Respondent was conducting advisory business in Rhode Island while not being properly registered with Rhode Island. This constitutes a violation of R.I. Gen. Laws § 7-11-203(b). c.) Both the Respondent and the investment adviser representative engaged in unregistered activity and such conduct is subject to penalties under R.I. Gen. Laws§ 7-11-602 Ill Based on the foregoing, the Division finds that the following is in the public interest, appropriate for the protection of investors, and consistent with the purposes intended by the policy and provisions of RIUSA. Accordingly, it is hereby further agreed that:

Respondent has ta ken all steps necessary to ensure full compliance with R.I. Gen. Laws§ 7-11-203 and all related rules and regulations. 2. Upon execution of this Agreement, Respondent shall pay an penalty of Three Thousand Dollars ($3,000.00) to the Department for violations of R.I. Gen. Laws§ 7-11-203. Payment instructions to follow under separate cover Respondent is hereby notified that any additional violations of the R.L Gen. Laws may be grounds for significant and substantial penalties -rJ.. Dated as of 3• day of o" f1.J9f,,,,.-; uiv3": Associate Director Securities, Commercial Licensing