Vestgen Investment Management, Llc

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, LOOSER CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE PARTICIPATED IN 14 PRIVATE SECURITIES TRANSACTIONS WITHOUT PROVIDING PRIOR WRITTEN NOTICE TO HIS MEMBER FIRM OR RECEIVING THE FIRM'S APPROVAL TO PARTICIPATE IN THE TRANSACTIONS. THE FINDINGS STATED THAT LOOSER DISCLOSED TO THE FIRM THAT HE WAS A CO-OWNER OF A COMPANY THAT DEVELOPED A VIDEO PLATFORM TO CONNECT ON-CALL INTERPRETERS WITH DEAF OR LIMITED LANGUAGE INDIVIDUALS. THE FIRM APPROVED THIS OUTSIDE BUSINESS ACTIVITY. HOWEVER, LOOSER WAS ALSO INVOLVED IN RAISING APPROXIMATELY $430,000 FOR THE COMPANY FROM THE SALE OF MEMBERSHIP UNITS TO 14 INVESTORS. LOOSER INTRODUCED AND DISCUSSED THE COMPANY WITH 13 FIRM CUSTOMERS (AND ONE NON-FIRM CUSTOMER) AND THEN REFERRED THOSE CUSTOMERS TO HIS CO-OWNER IN THE COMPANY TO INVEST. LOOSER DISCUSSED SUBSCRIPTION AGREEMENTS WITH AT LEAST FOUR OF THE INVESTORS AND RECEIVED INVESTMENT CHECKS FROM TWO INVESTORS, WHICH HE FORWARDED TO THE CO-OWNER OF THE COMPANY. LOOSER DID NOT RECEIVE SELLING COMPENSATION FOR ANY INVESTMENTS IN THE COMPANY. LOOSER'S FIRM DID NOT OFFER THE MEMBERSHIP UNITS IN THE COMPANY. Status: Final Sanction Detail: SANCTION TYPE - SUSPENSION REGISTRATION CAPACITIES AFFECTED: ALL CAPACITIES DURATION - FOUR MONTHS EXACT START DATE 06/04/2018 EXACT END DATE 10/03/2018 EXACT Summary: N/A