---

On December 15, 2017, the Banking Commissioner entered a Consent Order (No. CO-17-8373-S) with respect to Senior Financial Advisors, Inc. of 1 Corporate Drive, Suite 105, Shelton, Connecticut 06484 and William Thomas Leavitt, president of the firm. The firm is registered as an investment adviser under the Connecticut Uniform Securities Act. The Consent Order was an outgrowth of an examination of the firm and a related investigation conducted by the Securities and Business Investments Division.

The Consent Order alleged that Senior Financial Advisors, Inc. violated Section 36b-31-14e(a) of the Regulations under the Act by failing to amend its Form ADV to reflect that it had custody of an advisory client's cash, bank accounts and/or securities. The custody issue arose when an advisory client, since deceased, designated Leavitt to act as sole trustee of the account upon the account owner's death. On December 10, 2017, Leavitt transferred trusteeship of the account to a third party. The Consent Order also alleged that the firm and Leavitt violated Section 36b-31-14e(a) of the Regulations by failing to amend their regulatory filings to reflect that they were doing business as “Senior Financial College Planning” and to explain the nature of that business. Senior Financial College Planning’s business purpose was to assist students with the college admissions process and to provide parents of college bound students with advice on managing finances. In addition, the Consent Order alleged that from January 1, 2016 to January 4, 2017, William Thomas Leavitt transacted business as an unregistered investment adviser agent in contravention of Section 36b-6(c)(2) of the Act, and that the firm unlawfully engaged Leavitt in an unregistered capacity in violation of Section 36b-6(c)(3) of the Act. The Consent Order acknowledged that the firm and Leavitt ultimately updated their regulatory filings and that Leavitt became registered as an investment adviser agent of the firm in Connecticut.

The Consent Order directed Senior Financial Advisors, Inc. and William Thomas Leavitt to cease and desist from regulatory violations and to pay a $10,000 fine to the department, jointly and severally. The Consent Order also required the firm to review and revise (as necessary) its written supervisory procedures within six months to ensure that the firm was in compliance with regulatory requirements governing custody and other matters.