NOTE: Stipulations of Fact and Consent to Penalty (SFC); Offers of Settlement (OS); and Letters of Acceptance Waiver, and Consent (AWC) are entered into by Respondents without admitting or denying the allegations, but consent is given to the described sanctions & to the entry of findings. Additionally, for AWCs, if FINRA has reason to believe a violation has occurred and the member or associated person does not dispute the violation, FINRA may prepare and request that the member or associated person execute a letter accepting a finding of violation, consenting to the imposition of sanctions, and agreeing to waive such member's or associated person's right to a hearing before a hearing panel, and any right of appeal to the National Adjudicatory Council, the SEC, and the courts, or to otherwise challenge the validity of the letter, if the letter is accepted. The letter shall describe the act or practice engaged in or omitted, the rule, regulation, or statutory provision violated, and the sanction or sanctions to be imposed.

Linda Jo Bartley and William Arthur Donaldson
AWC/2005003504002/#2

Bartley's and Donaldson's member firm entered into a “Selling Agreement” with a company to serve as a selling agent for the company’s offering and sold the unregistered offering pursuant to an exemption from SEC registration pursuant to Regulation D. Acting on the firm’s behalf, Bartley and Donaldson sold interests in the company’s offering to investors with whom neither they nor the firm had any pre-existing relationship prior to the time that they contacted them relating to a potential investment in the offering company, thus engaging in a general solicitation with respect to the offering. Bartley sent a document to prospective investors relating to the offering, which was not fair and balance, omitted material risks relating to the offering, and she failed to obtain approval from a firm principal prior to sending the document to prospective investors. 

Linda Jo Bartley: Fined $15,000; Suspended 2 months in all capacities

William Arthur Donaldson: Fined $5,000; Suspended 1 month in all capacities