Virginia SCC v. Tribble - Unregistered Advisory and Material Fraud

251220032 OFVIRGINIACOMMONWEALTH

COMMISSIONCORPORATIONSTATE Corporation State

ControlDocument Center RICHMOND,ATDECEMBER5,12/5/2025-8:38 AM

rel.ex VIRGINIA, COMMONWEALTH OF COMMISSION STATECORPORATION NO. CASE SEC-2024-00046v. WILLIAMTRIBBLE, Defendant TORULE SHOW CAUSE Division Franchising the State Theand " Division " ) CorporationofRetail ( of ),the following against allegations William ""(makes Tribble Defendant Virginia Code "),to 12.1-13 Code"Tribble pursuant § "or" of the of ( " " and( )

etseq.of and B "§13.1-501§§ theVirginia ), the13.1-504A13.1-503Act" (Act of Code.

1. Summary Division alleges October and 2021, The between 2020 that February Tribble1. of the in§ 13.1-504A Act by advisory businessviolated this as with Division Commonwealth not the exempt whenhe was nor from requiredbyAct. the byThe Division that § the Act alleges violated 13.1-503 also Tribble B of making2. several material when misrepresentations his clients by that or omissions identifying he firm formally created with had that never been orwasan registered, of investments had and his guarantying client means so when doing he no misstating status.advisor

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violatedthe requests that the that Division find Tribble3. and of Act. 13.1-50413.1-503 B To these A the address the Division respectfully §§ violations, requests the that civil penalties and costs theCommission:(a) impose of against Defendant; (b) clients; enter to to (c) require provide a permanentTribble as advisor, representative, barring acting broker Tribblefrom advisor or or dealer selling Virginia orbroker-dealeragent,oroffering in from being without (d) other registered; and for that properly all such relief the deems Code. Act and pursuant to thethe

1. Background who purported Tribble a resident Virginia established advisoryis a4. business as around 2020. and the known (the " inHanAllenHedge Fund " ) or October Tribble heldthemselvesoutas business Richmond, in all relevantconducting times,Fund Virginia at as Tribble never business the formal entity.thoughformed Fund a advisor,Tribble never in as has been an Virginia5. representative, broker-dealer or agent.advisor broker dealer Despite not registered, and October being between 2021, 2020 February Tribble6. six Management with " )enteredinto" client " " at least different ( investors Investors advisory where to services LA to these Investors "Tribbleagreed (provide In these Agreements, held out as being ). Tribble himself with"each of IA and behalfofpurported Fund.acting the on Through Agreements, the Tribble Fund) theIA (and the supposed 7. Investors hired advisory Agreements, assertedto services. these IA Tribble through Further,provide as advisory and wouldact thathethe regarding theFund fiduciaries services offered

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and Tribble ' Investors. with material Investors,provided to the s the was to the affiliation Fund as perception Tribble of established organization. fostered the that was anit part required a with 8. The IA to each account Investor open brokerage Brokers, then grant custody and Tribble and authority over to the select account(s)Interactive and deemed purchase that Tribble for Investor. the The Investors also granted Tribble and direct, and and the authority to the manage change Fund in vehicles. reinvestment these assets and of various Each relied Investor select purchases. Tribble ' advice and claimed to upon s the expertise In IA stated for these Tribble exchange the that services, would be 9. compensated Fee " with Fee to fee " Schedule the agreement. The pursuant a schedule ( ) provided pay: 2.0% provided would of Schedule that Investor (a) to the value their each 1.0% of assets sliding AUM ), scale, total placed with Tribble;under management " based the ( AUM " on a on [withdrew]and profit of they funds. 20% any their Principal time " on top each "(b) of a between Investor $1,000 to with principal amount $10,000 Each invested 10. as as Agreement, well in IA wouldTribble. each Investor the that Tribble informed verbally, he guaranty purported guaranty the their with him. This material initial principal was to invest Tribble. ' to with decisionsInvestors its investigation, the Division asserts that Tribble did not based on have However, 11. of ability to guaranty investmentsthe the the Investors ' or financial means entirety principal Notably, initial with him. their sixmade requesting investments, despite a return of none of the who with been their had IA have refunded principalInvestors Tribble amounts.

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included disclosure in IA exempt the that Further,Tribble a he was "12. [Securities with with and Exchange in applicablethe Commission]from accordance as this not " disclosure that was anlaw(s),butomittedfrom he representative in advisor required pursuant to theoradvisor as Virginia Act. were they to Investors, because on Tribble 'These the disclosures material relied s13. stated statusas invest when to with him.regulatory advisor deciding acompliant Based ' and Division activities, representations omissions, theuponTribbles14. further violated as discussed assertsthat Tribble theAct below.has

Requested III.Violationsand Remedies § the advisory violated 13.1-504 providing A of Tribble ActA. by without being services registered. 13.1-504 any inSection A the Act prohibits person business of from15. as or with advisor unless representativeVirginiaanadvisor the as a and noticed filed federallyDivisionor covered advisor. as 13.1-501 of defines advisor Section the Act an an or individual16. businesswho compensation, business the " in . . as toentity the advisingfor engages of others ofas selling " tothe advisability in, value purchasing, oror of investing and who holdthemselves providing advisoryincludes those" out the services as foregoing to for otherscompensation." representative is with associatedAn advisor an individual an17. who any recommendations advice advisor makes "(i) or renders regarding otherwise of recommendations accounts clients, (iii) (ii) securities,manages or portfolios determines which or be advice prepares reports concerningregarding or analyses should given, (iv)

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ornegotiates ofsecurities,(v)offers for the sellssolicits, or advisory[and] sale services." asserts held as providingThe Divisionthat Tribble himself out18. advisory with toservices,enteringinto Investors compensation at least six forIA advisory Division further advised and providesendees.The alleges that Tribble accounts, as well and the Investors' brokerage as purchased onmanagedthe selected Investors 'behalf Divisionasserts not the asHowever, with the that Division Tribble was19. as advisoror Act. advisor representative an by required the Nor was as otherwise a advisor exemptcovered or fromTribblefederally registration. § asserts Act Division that A the Tribble violated 13.1-504 of the on20. not six advisory though and occasions by providing services atleast underto the so.Actdo

misleadingB. §13.1-503 the Tribble of by making untrue or violated B Act whenstatements client Investors. Sectionof [i]n 13.1-503 B provides, part, Act in that " the solicitation the relevant21. for untrue any make any statement materialadvisory itbe person to aofclients,shallunlawful of order fact, omit to material fact in to make the statements made . .. orstatea notnecessary misleading." When Tribble Investors to advisory the become his clients,22. (a) though it informed that: he with never the Fund, had been createdwas theInvestors or a entity;(b) guaranty as their when business principal hehe would investment, as notand (c) acting had no means and that their coulddoingso; he was advisorof 5

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and with U.S. and thewasexemptfrom Exchange while or with never with as thethathehad a exemption requiredomitting sought Division. As representations such,asserts ' Division that Tribble regarding thesethe s23. were material, and inaccurate.mattersfalse alleges at Division that § leastthe Tribble violated 13.1-503 B on24. these sixoccasions by making misrepresentations when the ormaterial omissions Investorsandpromotingand into the Agreements.entering IA

RemediesC.Requested

Division asks (a) and the the civil impose to: penalties25. costsas and of of 5 A Act; the pursuant to§§ 13.1-518 21 (b) require as (c) toprovideto under § Act; the 13.1-521 C enter aTribbleInvestors of barring as permanent acting an advisor,Tribble from advisor dealer selling broker or orrepresentative, dealer, agent offering in or frombroker pursuant unless to so; to 13.1-519 otherwise (d) TribbleVirginia § barof Actthe do and/or (e) other violations to 13.1-519 Act; the pursuant § the suchfromfurtherofAct of impose deemed remediesas under penalties,fines,or the Act. ISORDERED IT THAT: has Case This assigned No. SEC-2024-00046.matterbeen and docketed1) In the of accordancewith5 VAC of and ' Practice 5-20-120 s Rules2)

etseq., 5 Code, matter assignedProcedure,VAC5-20-10, Virginia Administrative this of the is who conduct all this behalf oftoa Hearing proceedings in case theExaminershall further on andfile a Report.Final

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hearing in this case 'The shall in the sExaminer aHearingconvene3) TylerBuilding, Main Richmond,1300 East Virginia, on May Courtroom,SecondFloor, Street, commencing a.m. as at10:00 and continuing thereafter During this2026, 7, necessary. hearing, Defendant not may why permanentlythe and showthe should appear Defendantcause be not in enjoined businessVirginia and enjoined from be permanently from thethe of violating future -519 Act; subject order Act in pursuant § the to an of13.1 to of §ofthe Act; and order costs and civil to to pursuant anpenalties13.1-521 subject imposing ofpursuant§13.1-518Act,due and to the alleged to his violations of §§ 13.1-504 the 13.1-503ofAct. orbefore 20, of with Clerk Onthe Defendant file the theJanuary2026, shall4) a which Defendant expressly admits or the in responsivepleading deniesthe allegationspresents allegations Show and any affirmative defenses the this to Cause to inRule Defendant assert.Defendant any the that the toIf presents affirmative defense,intendsthe Defendantset full all and shallforthin the pleading a responsive clear statement of the facts Defendantisprepared the provesuch defense. uponwhichto affirmative The Defendant shall or expresslyindicatein pleading desires to such whether not and appear responsive he intends heardthe date. and before onthe scheduled hearing not filed beExaminer Hearing If electronically, Defendant original shallan and (15) thethefile fifteen copies of responsive with P.O. Box the c/o pleadingClerkDocumenttheof Control Center, 2118, theRichmond, Virginia contain the 23218.Theresponsivepleading shall caption setting forth

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pleading this of case and A ' in this the s styleitsnumber. copy of Defendant matter responsive 1 Office of to Examiners.beelectronically the Hearingshallalsosent may either a in fails timely TheDefendant be default if he to found file responsive5) asset otherpleading above or files and fails to such forth he pleadingor pleading, if to hearing. files fails makeatthescheduled the such pleading and an Defendantappearance If the may in makeatthe default,anappearancehearing, he be found default. found in If deemed admissibility of and to waived all the Defendantshallbe have objections to evidence may a pursuant entered against judgment by imposing to havehim an default; of of13.1-519ofAct, pursuant to Act, and costs§ the and penalties § the 13.1-521 of Act. to § pursuant the13.1-518 may settlement matter telephoningThe to negotiate this Defendant a by offer of6) of negotiatedOffice at Any the 371-9671. to (804) settlement is subjectGeneralCounsel by theapprovalCommission. hereof of MAIL, COPY the Clerk the byshall be sent by CERTIFIED 703, RECEIPT REQUESTED Street, UnitRETURN William 301 Virginia to: Tribble Richmond, of and a delivered ' GeneralVirginia23219; to the s copy shall be Office and of and Retail theDivision Counsel Franchising.

be be 1 Theelectroniccopy shall sent to: . such copy is to sent OHEParalegals@scc.virginia.govunableIf mailedHearing Boxelectronically,itshall be to: State Examiners,P.O. 1197, CorporationofOffice ARichmond, 23218.Virginia 8