Linda Jo Bartley, Registered Representative of Haslett, Michigan and William Arthur Donaldson, a Registered Representative ofYorba Linda, California submitted Letters of Acceptance,Waiver and Consent in which Bartley was fined $15,000 and suspended from association with any FINRA member in any capacity for two months. Donaldson was fined $5,000 and suspended from association with any FINRA member in any capacity for one month. The respective fines must be paid either immediately upon their respective reassociation with a FINRA member firm following the suspension, or prior to the filing of any application or request for relief from any statutory disqualification, whichever is earlier. Without admitting or denying the findings, Bartley and Donaldson consented to the described sanctions and to the entry of findings that their 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. The findings stated that Bartley and Donaldson, acting on the firm’s behalf, 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. The findings also stated that Bartley, Donaldson and the firm used the means of interstate commerce to offer and effect these transactions, thus engaging in a general solicitation with respect to the offering. The findings also included that 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.

Bartley’s suspension is in effect from August 17, 2009, through October 16, 2009. Donaldson’s suspension was in effect from August 17, 2009, through September 16, 2009. (FINRA Cases #2005003504002/#2005003504003)