ADMINISTRATIVE PROCEEDING
File No. 3-21782

October 11, 2023 - The Securities and Exchange Commission today announced settled charges against Jason Todd Reynolds and Collaborative Financial Consulting LLC ("Collaborative") for statements in a document provided to prospective and existing clients that gave misleading impressions about Reynolds' qualifications and securities industry registrations.

According to the Order, Collaborative and Reynolds held themselves out publicly as investment advisers and marketed the services Reynolds provided through a website, publications, and a podcast. The Order states that from 2019 to 2021, Reynolds provided Client Agreements to prospective and existing clients that characterized Reynolds as "an Investment Adviser Representative ('Investment Advisory Representative') holding Series 7, 66, 63 licenses in CA, NV, ID, PA, NY, WV, GA, TN." While Reynolds previously had been a registered representative and investment adviser representative, associated with broker-dealers and investment advisers registered with the Commission, those registrations had terminated on June 26, 2019.

According to the Order, at the time Reynolds drafted the representations included in the Client Agreements, he knew or should have known that he was not registered as an investment adviser or broker-dealer with the Commission or any state, or associated with a registered broker-dealer, or registered with one or more states as an investment adviser representative. As a result, the SEC finds that Collaborative's Client Agreements gave misleading impressions about Reynolds' qualifications and that Reynolds held active securities industry registrations related to the investment advice he was providing to clients through Collaborative.

The California Department of Financial Protection and Innovation ("DFPI") also issued a parallel Desist and Refrain Order against Reynolds and Collaborative.

The SEC's order finds that Reynolds and Collaborative violated Section 206(2) of the Investment Advisers Act of 1940 ("Advisers Act"). Without admitting or denying the findings in the order, Reynolds and Collaborative agreed to a cease-and-desist order; a censure for Collaborative; securities industry bars and prohibitions for Reynolds with the right to apply for reentry after three years; and a civil money penalty in the amount of $20,000 with payment deemed satisfied by the issuance of the parallel DFPI Order, which imposes a penalty in the same amount.

The SEC's investigation was conducted by Adam Eisner, Keith A. O'Donnell, Karaz Zaki and supervised by C. Joshua Felker, Dwayne Brown, and Melissa Hodgman. The SEC acknowledges the assistance of the California Department of Financial Protection & Innovation and the Financial Industry Regulatory Authority (FINRA).