Queen B Advisors, Llc

Allegations: QB AND MS. WILLY AGREED TO THE ENTRY OF THE CONSENT ORDER THAT FOUND IN CONNECTION WITH MS. WILLY'S INVESTMENT ADVISORY SERVICES AT HER PRIOR FIRM, MS. WILLY AND OTHER AGENTS OF TFA, WHO WERE NOT REGISTERED DEALERS OR AGENTS OF DEALERS, RECOMMENDED THAT CLIENTS PURCHASE CERTAIN ALTERNATIVE INVESTMENTS WHICH WERE DEEMED TO BE SECURITIES BY THE TSSB. THE CONSENT ORDER ALSO FOUND THAT MS. WILLY FAILED TO DISCLOSE TO HER PRIOR FIRM AND TO UPDATE HER FORM U4 THAT SHE WAS ENGAGING IN THE SALE OF THESE ALTERNATIVE INVESTMENTS IN VIOLATION OF TSSB RULES. THE CONSENT ORDER FOUND THAT WILLY FAILED TO CONDUCT A REASONABLE LEVEL OF DUE DILIGENCE TO DETERMINE THE SUITABILITY OF THE ALTERNATIVE INVESTMENTS OR THE AMOUNT INVESTED PRIOR TO MAKING HER RECOMMENDATIONS. THESE ACTIONS CONSTITUTED INEQUITABLE PRACTICES AND VIOLATIONS UNDER SECTIONS 12 AND 14 OF THE TEXAS SECURITIES ACT. Status: Final Sanction Detail: WILLY'S REGISTRATION AS AN INVESTMENT ADVISOR REPRESENTATIVE SUSPENDED 10/2020-10/2021. NO DISCRETIONARY TRADING FROM 10/2020-10/2025. NO SALE, RECOMMENDATION OR REFERRAL OF ALTERNATIVE INVESTMENTS FROM 10/2020-10/2025. QB AND WILLY AGREED TO AN UNDERTAKING WHEREBY THEY AGREED TO REFUND $2,750,500 IN COMMISSIONS WHO PURCHASED ALTERNATIVE INVESTMENTS RECOMMENDED BY AGENTS OF TEXAS FINANCIAL ADVISORY ("TFA"). QB AND WILLY AGREED NOT TO EXERCISE DISCRESTIONARY TRADING AUTHORITY OR RECOMMEND ANY ALTERNATIVE INVESTMENT (OR REFERRAL OF ANY CLIENTS TO ANY INVESTMENT ADVISER WHO DOES SO) FOR FIVE YEARS. Summary: THE CONSENT ORDER GRANTED REGISTRATION OF QB AS AN INVESTMENT ADVISOR AND WILLY AS AN INVESTMENT ADVISOR REPRESENTATIVE OF QB. WILLY'S SUSPENSION AS AN INVESTMENT ADVISOR REPRESENTATIVE ENDED 10/2021. WILLY AND QB HAVE COMPLETED THE UNDERTAKING TO REFUND $2,750,500 IN COMMISSIONS TO CLIENTS WHO PURCHASED THE ALTERNATIVE INVESTMENTS FROM TFA. WILLY AND QB ALSO AGREED TO RETAIN AN OUTSIDE COMPLIANCE CONSULTANT (WITH CERTAIN HEIGHTENED REVIEW AND REPORTING DUTIES). WILLY AND QB REMAIN SUBJECT TO THEIR AGREEMENT NOT TO REFER OR RECOMMEND ALTERNATIVE INVESTMENTS OR EXERCISE DISCRETIONARY TRADING AUTHORITY THRU 10/2025.