In re CORY D. WILLIAMS

 
 UNITED STATES OF AMERICA 
 Before the 
 SECURITIES AND EXCHANGE COMMISSION 
 
 
SECURITIES EXCHANGE ACT OF 1934 
Release No. 75691 / August 13, 2015 
 
INVESTMENT ADVISERS ACT OF 1940 
Release No. 4171 / August 13, 2015 
 
INVESTMENT COMPANY ACT OF 1940 
Release No. 31752 / August 13, 2015 
 
ADMINISTRATIVE PROCEEDING  
File No. 3-16754 
 
In the Matter of 
 
 
CORY D. WILLIAMS  
 
 
Respondent 
 
 
 
 
ORDER INSTITUTING ADMINISTRATIVE 
AND CEASE-AND-DESIST PROCEEDINGS, 
PURSUANT TO SECTION 15(b) OF THE 
SECURITIES EXCHANGE ACT OF 1934, 
SECTIONS 203(f) AND 203(k) OF THE 
INVESTMENT ADVISERS ACT OF 1940, 
AND SECTION 9(b) OF THE INVESTMENT 
COMPANY ACT OF 1940, MAKING 
FINDINGS, AND IMPOSING REMEDIAL 
SANCTIONS AND A CEASE-AND-DESIST 
ORDER  
 
I. 
 
 The Securities and Exchange Commission (“Commission”) deems it appropriate and in the 
public interest that public administrative and cease-and-desist proceedings be, and hereby are, 
instituted pursuant to Section 15(b) of the Securities Exchange Act of 1934 (“Exchange Act”), 
Sections 203(f) and 203(k) of the Investment Advisers Act of 1940 (“Advisers Act”), and Section 
9(b) of the Investment Company Act of 1940 (“Investment Company Act”) against Cory D. 
Williams (“Williams” or “Respondent”).   
 
II. 
 
 In anticipation of the institution of these proceedings, Respondent has submitted an Offer 
of Settlement (“Offer”) that the Commission has determined to accept.  Solely for the purpose of 
these proceedings and any other proceedings brought by or on behalf of the Commission, or to 
which the Commission is a party, and without admitting or denying the findings herein, except as 
to the Commission’s jurisdiction over him and the subject matter of these proceedings, which are 

 
2 
admitted, and except as provided herein in Section V, Respondent consents to the entry of this  
Order Instituting Administrative and Cease-and-Desist Proceedings, Pursuant to Section 15(b) of 
the Securities Exchange Act of 1934, Sections 203(f) and 203(k) of the Investment Advisers Act of 
1940, and Section 9(b) of the Investment Company Act of 1940, Making Findings, and Imposing 
Remedial Sanctions and a Cease-and-Desist Order (“Order”), as set forth below.   
 
III. 
 
 On the basis of this Order and Respondent’s Offer, the Commission finds
1
 that: 
 
Summary 
 
 This matter concerns the involvement of Cory D. Williams, a former registered 
representative and investment adviser representative at Signator Investors, Inc. (“Signator”), a 
dually registered investment adviser and broker-dealer, in a fraudulent offering scheme and 
investment advisory fraud principally orchestrated by his partner James R. Glover, also a former 
Signator registered representative and investment adviser representative.  While associated with 
Signator, from approximately May 1998 through May 2012, Glover conducted an offering fraud 
that defrauded at least 125 Signator advisory clients and brokerage customers of approximately 
$13.5 million by soliciting them to invest in Colonial Tidewater Realty Income Partners, LLC 
(“Colonial Tidewater”), a security not approved for sale by Signator representatives.  Glover made 
materially false and misleading statements regarding the financial health of Colonial Tidewater, the 
expected returns and risk of investing, and deceived investors by, among other things, creating the 
false impression that Colonial Tidewater was a Signator-approved investment. 
 
 Williams assisted Glover in managing Signator advisory client portfolios, including those 
clients who invested in Colonial Tidewater.  While he lacked sufficient information to know that 
Glover’s statements to investors were false, Williams did accept undisclosed fees from Colonial 
Tidewater.  As an investment adviser, Williams had a fiduciary duty to disclose material conflicts of 
interest to his clients and to act in their best interests.  Williams breached this duty by accepting 
quarterly commission payments from Colonial Tidewater that were not disclosed to the Signator 
advisory clients he serviced.  These payments, which came from monies invested by his advisory 
clients in Colonial Tidewater, disadvantaged Williams’ clients while benefitting Williams.  
Further, Williams knew that a substantial number of his advisory clients were investing in Colonial 
Tidewater, but he knew virtually nothing about this unregistered offering, except that it was not an 
investment sanctioned or approved by Signator.  When clients complained to Williams regarding 
problems with their investments in Colonial Tidewater, he ignored these red flags, continued to act 
as their investment adviser, and continued to receive payments from Colonial Tidewater.  Based on 
these actions, Williams willfully violated Sections 206(1) and 206(2) of the Advisers Act.   
                                                 
1
  The findings herein are made pursuant to Respondent’s Offer of Settlement and are not 
binding on any other person or entity in this or any other proceeding.  
 

 
3 
 
Respondent 
 
 1. Cory D. Williams, age 43, is a resident of Monkton, Maryland.  He was a registered 
representative and investment adviser representative in Signator’s Towson, Maryland Office of 
Supervisory Jurisdiction (“Towson OSJ”) from April 30, 1998 through March 7, 2013, when his 
employment was terminated.  From April 2013 through September 2013, Williams was a registered 
representative and investment adviser representative associated with a broker-dealer and investment 
adviser registered with the Commission.  He holds series 6, 7, 63, and 65.      
 
Other Relevant Person and Entities 
 
 2. James R. Glover, age 73, is a resident of White Hall, Maryland.  He was a registered 
representative and investment adviser representative in Signator’s Towson OSJ from May 1, 1998 
through May 11, 2012, when he was permitted to resign.  He held series 6, 22, 63, and 65.       
 
3. Signator Investors, Inc., headquartered in Boston, Massachusetts, is a registered 
broker-dealer and investment adviser.   
 
4. Colonial Tidewater Realty Income Partners, LLC is a Maryland limited liability 
company which was formed on January 26, 1999.  Colonial Tidewater is not registered with the 
Commission.  Glover has been a managing member since April 1, 2004.  The company’s principal 
office is located in Conowingo, Maryland.  Colonial Tidewater owns and operates residential and 
commercial properties through its subsidiaries in Maryland, Pennsylvania, and New York.   
 
Background 
 
5. In May 1998, Glover and Williams joined Signator’s Towson OSJ.  The two had 
previously worked together at another broker-dealer located in Towson, where Williams had begun 
his career under Glover’s tutelage.   
 
6. Glover and Williams shared most of their clients.  Some of these clients were 
brokerage customers, some were advisory clients, and many had both brokerage and advisory 
relationships with Glover and Williams.  Together, Glover and Williams provided their clients a 
broad array of financial products in addition to brokerage and investment advisory services, 
including annuities, and long term care and life insurance.   
 
7. As an investment adviser, Williams understood that he owed his advisory clients a 
fiduciary duty and was required to disclose compensation he received from sources that would 
render his advice conflicted.  
 
8. As Williams gained experience and began developing his own clients as well as 
servicing Glover’s clients, Williams gradually received a greater percentage of the income 
generated from Glover’s business.  During the applicable time period, Glover and Williams 
shared much of the income generated from their business relationship 50/50.   

 
4 
 
9. From approximately January 1999 through May 2012, Glover solicited their 
Signator brokerage and advisory clients asking that they invest in partnership units issued by 
Colonial Tidewater, which was not a Signator-approved investment.  Ultimately, at least 125 
brokerage and advisory clients agreed to invest a total of approximately $13.5 million.  Glover 
solicited these investments through myriad misrepresentations.  
 
10. While Williams did not solicit advisory clients to invest in Colonial Tidewater, he 
knew that Glover was selling the investment to many of their shared advisory clients.  Williams 
also knew the Colonial Tidewater investment was not authorized or approved by Signator.   
 
 11. Williams provided investment advice to clients and managed client portfolios.  For 
example, Williams participated in client meetings during which Colonial Tidewater was discussed.  
Williams was present for internal meetings with Glover and their assistant at which they discussed 
specific client portfolios, including advisory clients’ holdings in Colonial Tidewater.  Williams 
communicated with Colonial Tidewater’s bookkeeper when clients needed account related 
information.  He also obtained information from Glover in response to client questions regarding 
Colonial Tidewater.   
 
 12. As Glover’s partner, Williams was aware that a significant number of his advisory 
clients had invested millions of dollars in Colonial Tidewater.  Yet Williams had very little 
understanding of the business of Colonial Tidewater, other than knowing that Glover had a 
relationship with the company and was selling the Colonial Tidewater investment to their clients. 
 
 13. Williams provided advisory clients with consolidated reports, also known as 
Albridge reports, to show clients that their overall financial holdings included positions 
maintained outside of Signator such as the Colonial Tidewater investment.  Williams’ name 
appeared on the top of each page of the Albridge reports provided to clients. 
 
 14.   Williams had the ability, through software licensed from Albridge Solutions, 
Inc., to manually add outside investments such as Colonial Tidewater to the reports, and he did 
so.  Through this same manual entry function, at times, Williams also added the purported value 
of his clients’ Colonial Tidewater investment to Albridge reports which were then emailed, 
mailed or otherwise given to advisory clients.   
 
15. Beginning in approximately 2005, Williams began receiving quarterly payments 
from Colonial Tidewater.  The payments were in the form of checks written from Colonial 
Tidewater’s bank account, the same account into which investor monies were deposited.  The 
checks averaged approximately three percent of new monies invested through Glover in Colonial 
Tidewater each quarter.  Williams received these payments through 2011.   
 
16. For every check that Williams received from Colonial Tidewater, he then paid half 
of the monies to Glover.  As a result of this arrangement, Williams received a 1.5 percent 
commission on all new investor monies brought into Colonial Tidewater by Glover each quarter.   

 
5 
In total, Williams received $188,382 from Colonial Tidewater from 2005 through 2011.  Williams 
paid half this sum to Glover, and kept the remaining $94,191 for himself.     
 
17. Williams never disclosed his receipt of these payments to his advisory clients or 
Signator.  Williams had a material conflict of interest in acting as an investment adviser for clients 
who held investments in Colonial Tidewater while receiving this undisclosed compensation from 
Colonial Tidewater.   
 
18. At least as early as mid-2011, Williams became aware of red flags with respect to 
Colonial Tidewater when clients complained about their inability to obtain repayment of their 
investments and the failure to receive account statements.  Williams never brought these concerns 
to the attention of anyone at Signator and never did any investigation into potential problems with 
Colonial Tidewater.  However, Williams continued to service clients in connection with their 
Colonial Tidewater investments and continued to receive payments from Colonial Tidewater for 
new investments by his advisory clients.    
 
19. On May 11, 2012, after Glover’s fraud came to light, Glover retired and Williams 
then assumed sole responsibility for all of their formerly joint advisory clients.  On March 7, 2013, 
Signator terminated Williams’ employment.         
 
Violations 
 
20. As a result of the conduct described above, Williams willfully violated Sections  
206(1) and 206(2) of the Advisers Act, which prohibit an investment adviser from employing any 
device, scheme, or artifice to defraud any client or prospective client, and from engaging in any 
transaction, practice, or course of business which operates as a fraud or deceit upon any client or 
prospective client.  
 
IV. 
 
 In view of the foregoing, the Commission deems it appropriate and in the public interest to 
impose the sanctions agreed to in Respondent William’s Offer. 
 
 Accordingly, pursuant to Sections 15(b) of the Exchange Act, Sections 203(f) and 203(k) 
of the Advisers Act, and Section 9(b) of the Investment Company Act, it is hereby ORDERED 
that: 
 
 A. Respondent Williams cease and desist from committing or causing any violations 
and any future violations of Sections 206(1) and 206(2) of the Advisers Act.   
 
B. Respondent Williams be, and hereby is: 
 
barred from association with any broker, dealer, investment adviser, 
municipal securities dealer, municipal advisor, transfer agent, or nationally 
recognized statistical rating organization;  

 
6 
 
prohibited from serving or acting as an employee, officer, director, member 
of an advisory board, investment adviser or depositor of, or principal 
underwriter for, a registered investment company or affiliated person of such 
investment adviser, depositor, or principal underwriter; and 
barred from participating in any offering of a penny stock, including: 
acting as a promoter, finder, consultant, agent or other person who 
engages in activities with a broker, dealer or issuer for purposes of the 
issuance or trading in any penny stock, or inducing or attempting to induce 
the purchase or sale of any penny stock.  
 C. Any reapplication for association by Respondent Williams will be subject to the 
applicable laws and regulations governing the reentry process, and reentry may be conditioned 
upon a number of factors, including, but not limited to, the satisfaction of any or all of the 
following:  (a) any disgorgement ordered against the Respondent, whether or not the Commission 
has fully or partially waived payment of such disgorgement; (b) any arbitration award related to the 
conduct that served as the basis for the Commission order; (c) any self-regulatory organization 
arbitration award to a customer, whether or not related to the conduct that served as the basis for 
the Commission order; and (d) any restitution order by a self-regulatory organization, whether or 
not related to the conduct that served as the basis for the Commission order. 
 
 D. Respondent Williams shall, within 10 days of the entry of this Order, pay 
disgorgement of $94,191, prejudgment interest of $9,854, and a civil money penalty in the amount 
of $94,191 to the Securities and Exchange Commission.  If timely payment of disgorgement and 
prejudgment interest is not made, additional interest shall accrue pursuant to SEC Rule of Practice 
600.  If timely payment of the civil money penalty is not made, additional interest shall accrue 
pursuant 31 U.S.C. § 3717.  Payment must be made in one of the following ways:   
 
(1) Respondent may transmit payment electronically to the Commission, which 
will provide detailed ACH transfer/Fedwire instructions upon request;  
 
(2) Respondent may make direct payment from a bank account via Pay.gov 
through the SEC website at http://www.sec.gov/about/offices/ofm.htm; or  
 
(3) Respondent may pay by certified check, bank cashier’s check, or United 
States postal money order, made payable to the Securities and Exchange 
Commission and hand-delivered or mailed to:  
 
Enterprise Services Center 
Accounts Receivable Branch 
HQ Bldg., Room 181, AMZ-341 
6500 South MacArthur Boulevard 
Oklahoma City, OK 73169 
 

 
7 
Payments by check or money order must be accompanied by a cover letter identifying 
Williams as the Respondent in these proceedings, and the file number of these proceedings; a copy 
of the cover letter and check or money order must be sent to G. Jeffrey Boujoukos, Associate 
Regional Director, Philadelphia Regional Office, Securities and Exchange Commission, 1617 JFK 
Boulevard, Suite 520, Philadelphia, PA 19103.   
 
 E.  Pursuant to Section 308(a) of the Sarbanes-Oxley Act of 2002, as amended, a Fair 
Fund is created for the disgorgement, interest and civil money penalty referenced in paragraph D 
above.  The disgorgement, interest and civil money penalty referenced in paragraph D above shall 
be distributed through a Fair Fund established in a related administrative proceeding arising out of 
the same underlying facts.  Amounts ordered to be paid as civil money penalties pursuant to this 
Order shall be treated as penalties paid to the government for all purposes, including all tax 
purposes.  To preserve the deterrent effect of the civil penalty, Respondent agrees that in any 
Related Investor Action, he shall not argue that he is entitled to, nor shall he benefit by, offset or 
reduction of any award of compensatory damages by the amount of any part of Respondent’s 
payment of a civil penalty in this action (“Penalty Offset”).  If the court in any Related Investor 
Action grants such a Penalty Offset, Respondent agrees that he shall, within 30 days after entry of 
a final order granting the Penalty Offset, notify the Commission’s counsel in this action and pay 
the amount of the Penalty Offset to the Securities and Exchange Commission.  Such a payment 
shall not be deemed an additional civil penalty and shall not be deemed to change the amount of 
the civil penalty imposed in this proceeding.  For purposes of this paragraph, a “Related Investor 
Action” means a private damages action brought against Respondent by or on behalf of one or 
more investors based on substantially the same facts as alleged in the Order instituted by the 
Commission in this proceeding. 
  
V. 
It is further Ordered that, solely for purposes of exceptions to discharge set forth in Section 
523 of the Bankruptcy Code, 11 U.S.C. § 523, the findings in this Order are true and admitted by 
Respondent, and further, any debt for disgorgement, prejudgment interest, civil penalty or other 
amounts due by Respondent under this Order or any other judgment, order, consent order, decree  
  

 
8 
or settlement agreement entered in connection with this proceeding, is a debt for the violation by 
Respondent of the federal securities laws or any regulation or order issued under such laws, as set 
forth in Section 523(a)(19) of the Bankruptcy Code, 11 U.S.C. § 523(a)(19). 
 
 
 By the Commission.  
 
 
 
       Brent J. Fields 
       Secretary 
 
 

UNITED STATES OF AMERICA 

 Before the 

 SECURITIES AND EXCHANGE COMMISSION 

 

 

SECURITIES EXCHANGE ACT OF 1934 

Release No. 75691 / August 13, 2015 

 

INVESTMENT ADVISERS ACT OF 1940 

Release No. 4171 / August 13, 2015 

 

INVESTMENT COMPANY ACT OF 1940 

Release No. 31752 / August 13, 2015 

 

ADMINISTRATIVE PROCEEDING  

File No. 3-16754 

 

In the Matter of 

 

 

CORY D. WILLIAMS  

 

 

Respondent 

 

 

 

 

ORDER INSTITUTING ADMINISTRATIVE 

AND CEASE-AND-DESIST PROCEEDINGS, 

PURSUANT TO SECTION 15(b) OF THE 

SECURITIES EXCHANGE ACT OF 1934, 

SECTIONS 203(f) AND 203(k) OF THE 

INVESTMENT ADVISERS ACT OF 1940, 

AND SECTION 9(b) OF THE INVESTMENT 

COMPANY ACT OF 1940, MAKING 

FINDINGS, AND IMPOSING REMEDIAL 

SANCTIONS AND A CEASE-AND-DESIST 

ORDER  

 

I. 

 

 The Securities and Exchange Commission (“Commission”) deems it appropriate and in the 

public interest that public administrative and cease-and-desist proceedings be, and hereby are, 

instituted pursuant to Section 15(b) of the Securities Exchange Act of 1934 (“Exchange Act”), 

Sections 203(f) and 203(k) of the Investment Advisers Act of 1940 (“Advisers Act”), and Section 

9(b) of the Investment Company Act of 1940 (“Investment Company Act”) against Cory D. 

Williams (“Williams” or “Respondent”).   

 

II. 

 

 In anticipation of the institution of these proceedings, Respondent has submitted an Offer 

of Settlement (“Offer”) that the Commission has determined to accept.  Solely for the purpose of 

these proceedings and any other proceedings brought by or on behalf of the Commission, or to 

which the Commission is a party, and without admitting or denying the findings herein, except as 

to the Commission’s jurisdiction over him and the subject matter of these proceedings, which are 



 2 

admitted, and except as provided herein in Section V, Respondent consents to the entry of this  

Order Instituting Administrative and Cease-and-Desist Proceedings, Pursuant to Section 15(b) of 

the Securities Exchange Act of 1934, Sections 203(f) and 203(k) of the Investment Advisers Act of 

1940, and Section 9(b) of the Investment Company Act of 1940, Making Findings, and Imposing 

Remedial Sanctions and a Cease-and-Desist Order (“Order”), as set forth below.   

 

III. 

 

 On the basis of this Order and Respondent’s Offer, the Commission finds1 that: 

 

Summary 

 

 This matter concerns the involvement of Cory D. Williams, a former registered 

representative and investment adviser representative at Signator Investors, Inc. (“Signator”), a 

dually registered investment adviser and broker-dealer, in a fraudulent offering scheme and 

investment advisory fraud principally orchestrated by his partner James R. Glover, also a former 

Signator registered representative and investment adviser representative.  While associated with 

Signator, from approximately May 1998 through May 2012, Glover conducted an offering fraud 

that defrauded at least 125 Signator advisory clients and brokerage customers of approximately 

$13.5 million by soliciting them to invest in Colonial Tidewater Realty Income Partners, LLC 

(“Colonial Tidewater”), a security not approved for sale by Signator representatives.  Glover made 

materially false and misleading statements regarding the financial health of Colonial Tidewater, the 

expected returns and risk of investing, and deceived investors by, among other things, creating the 

false impression that Colonial Tidewater was a Signator-approved investment. 

 

 Williams assisted Glover in managing Signator advisory client portfolios, including those 

clients who invested in Colonial Tidewater.  While he lacked sufficient information to know that 

Glover’s statements to investors were false, Williams did accept undisclosed fees from Colonial 

Tidewater.  As an investment adviser, Williams had a fiduciary duty to disclose material conflicts of 

interest to his clients and to act in their best interests.  Williams breached this duty by accepting 

quarterly commission payments from Colonial Tidewater that were not disclosed to the Signator 

advisory clients he serviced.  These payments, which came from monies invested by his advisory 

clients in Colonial Tidewater, disadvantaged Williams’ clients while benefitting Williams.  

Further, Williams knew that a substantial number of his advisory clients were investing in Colonial 

Tidewater, but he knew virtually nothing about this unregistered offering, except that it was not an 

investment sanctioned or approved by Signator.  When clients complained to Williams regarding 

problems with their investments in Colonial Tidewater, he ignored these red flags, continued to act 

as their investment adviser, and continued to receive payments from Colonial Tidewater.  Based on 

these actions, Williams willfully violated Sections 206(1) and 206(2) of the Advisers Act.   

                                                 
1
  The findings herein are made pursuant to Respondent’s Offer of Settlement and are not 

binding on any other person or entity in this or any other proceeding.  

 



 3 

 

Respondent 

 

 1. Cory D. Williams, age 43, is a resident of Monkton, Maryland.  He was a registered 

representative and investment adviser representative in Signator’s Towson, Maryland Office of 

Supervisory Jurisdiction (“Towson OSJ”) from April 30, 1998 through March 7, 2013, when his 

employment was terminated.  From April 2013 through September 2013, Williams was a registered 

representative and investment adviser representative associated with a broker-dealer and investment 

adviser registered with the Commission.  He holds series 6, 7, 63, and 65.      

 

Other Relevant Person and Entities 

 

 2. James R. Glover, age 73, is a resident of White Hall, Maryland.  He was a registered 

representative and investment adviser representative in Signator’s Towson OSJ from May 1, 1998 

through May 11, 2012, when he was permitted to resign.  He held series 6, 22, 63, and 65.       

 

3. Signator Investors, Inc., headquartered in Boston, Massachusetts, is a registered 

broker-dealer and investment adviser.   

 

4. Colonial Tidewater Realty Income Partners, LLC is a Maryland limited liability 

company which was formed on January 26, 1999.  Colonial Tidewater is not registered with the 

Commission.  Glover has been a managing member since April 1, 2004.  The company’s principal 

office is located in Conowingo, Maryland.  Colonial Tidewater owns and operates residential and 

commercial properties through its subsidiaries in Maryland, Pennsylvania, and New York.   

 

Background 

 

5. In May 1998, Glover and Williams joined Signator’s Towson OSJ.  The two had 

previously worked together at another broker-dealer located in Towson, where Williams had begun 

his career under Glover’s tutelage.   

 

6. Glover and Williams shared most of their clients.  Some of these clients were 

brokerage customers, some were advisory clients, and many had both brokerage and advisory 

relationships with Glover and Williams.  Together, Glover and Williams provided their clients a 

broad array of financial products in addition to brokerage and investment advisory services, 

including annuities, and long term care and life insurance.   

 

7. As an investment adviser, Williams understood that he owed his advisory clients a 

fiduciary duty and was required to disclose compensation he received from sources that would 

render his advice conflicted.  

 

8. As Williams gained experience and began developing his own clients as well as 

servicing Glover’s clients, Williams gradually received a greater percentage of the income 

generated from Glover’s business.  During the applicable time period, Glover and Williams 

shared much of the income generated from their business relationship 50/50.   



 4 

 

9. From approximately January 1999 through May 2012, Glover solicited their 

Signator brokerage and advisory clients asking that they invest in partnership units issued by 

Colonial Tidewater, which was not a Signator-approved investment.  Ultimately, at least 125 

brokerage and advisory clients agreed to invest a total of approximately $13.5 million.  Glover 

solicited these investments through myriad misrepresentations.  

 

10. While Williams did not solicit advisory clients to invest in Colonial Tidewater, he 

knew that Glover was selling the investment to many of their shared advisory clients.  Williams 

also knew the Colonial Tidewater investment was not authorized or approved by Signator.   

 

 11. Williams provided investment advice to clients and managed client portfolios.  For 

example, Williams participated in client meetings during which Colonial Tidewater was discussed.  

Williams was present for internal meetings with Glover and their assistant at which they discussed 

specific client portfolios, including advisory clients’ holdings in Colonial Tidewater.  Williams 

communicated with Colonial Tidewater’s bookkeeper when clients needed account related 

information.  He also obtained information from Glover in response to client questions regarding 

Colonial Tidewater.   

 

 12. As Glover’s partner, Williams was aware that a significant number of his advisory 

clients had invested millions of dollars in Colonial Tidewater.  Yet Williams had very little 

understanding of the business of Colonial Tidewater, other than knowing that Glover had a 

relationship with the company and was selling the Colonial Tidewater investment to their clients. 

 

 13. Williams provided advisory clients with consolidated reports, also known as 

Albridge reports, to show clients that their overall financial holdings included positions 

maintained outside of Signator such as the Colonial Tidewater investment.  Williams’ name 

appeared on the top of each page of the Albridge reports provided to clients. 

 

 14.   Williams had the ability, through software licensed from Albridge Solutions, 

Inc., to manually add outside investments such as Colonial Tidewater to the reports, and he did 

so.  Through this same manual entry function, at times, Williams also added the purported value 

of his clients’ Colonial Tidewater investment to Albridge reports which were then emailed, 

mailed or otherwise given to advisory clients.   

 

15. Beginning in approximately 2005, Williams began receiving quarterly payments 

from Colonial Tidewater.  The payments were in the form of checks written from Colonial 

Tidewater’s bank account, the same account into which investor monies were deposited.  The 

checks averaged approximately three percent of new monies invested through Glover in Colonial 

Tidewater each quarter.  Williams received these payments through 2011.   

 

16. For every check that Williams received from Colonial Tidewater, he then paid half 

of the monies to Glover.  As a result of this arrangement, Williams received a 1.5 percent 

commission on all new investor monies brought into Colonial Tidewater by Glover each quarter.   



 5 

In total, Williams received $188,382 from Colonial Tidewater from 2005 through 2011.  Williams 

paid half this sum to Glover, and kept the remaining $94,191 for himself.     

 

17. Williams never disclosed his receipt of these payments to his advisory clients or 

Signator.  Williams had a material conflict of interest in acting as an investment adviser for clients 

who held investments in Colonial Tidewater while receiving this undisclosed compensation from 

Colonial Tidewater.   

 

18. At least as early as mid-2011, Williams became aware of red flags with respect to 

Colonial Tidewater when clients complained about their inability to obtain repayment of their 

investments and the failure to receive account statements.  Williams never brought these concerns 

to the attention of anyone at Signator and never did any investigation into potential problems with 

Colonial Tidewater.  However, Williams continued to service clients in connection with their 

Colonial Tidewater investments and continued to receive payments from Colonial Tidewater for 

new investments by his advisory clients.    

 

19. On May 11, 2012, after Glover’s fraud came to light, Glover retired and Williams 

then assumed sole responsibility for all of their formerly joint advisory clients.  On March 7, 2013, 

Signator terminated Williams’ employment.         

 

Violations 

 

20. As a result of the conduct described above, Williams willfully violated Sections  

206(1) and 206(2) of the Advisers Act, which prohibit an investment adviser from employing any 

device, scheme, or artifice to defraud any client or prospective client, and from engaging in any 

transaction, practice, or course of business which operates as a fraud or deceit upon any client or 

prospective client.  

 

IV. 

 

 In view of the foregoing, the Commission deems it appropriate and in the public interest to 

impose the sanctions agreed to in Respondent William’s Offer. 

 

 Accordingly, pursuant to Sections 15(b) of the Exchange Act, Sections 203(f) and 203(k) 

of the Advisers Act, and Section 9(b) of the Investment Company Act, it is hereby ORDERED 

that: 

 

 A. Respondent Williams cease and desist from committing or causing any violations 

and any future violations of Sections 206(1) and 206(2) of the Advisers Act.   

 

B. Respondent Williams be, and hereby is: 

 

barred from association with any broker, dealer, investment adviser, 

municipal securities dealer, municipal advisor, transfer agent, or nationally 

recognized statistical rating organization;  



 6 

 

prohibited from serving or acting as an employee, officer, director, member 

of an advisory board, investment adviser or depositor of, or principal 

underwriter for, a registered investment company or affiliated person of such 

investment adviser, depositor, or principal underwriter; and 

barred from participating in any offering of a penny stock, including: 

acting as a promoter, finder, consultant, agent or other person who 

engages in activities with a broker, dealer or issuer for purposes of the 

issuance or trading in any penny stock, or inducing or attempting to induce 

the purchase or sale of any penny stock.  

 C. Any reapplication for association by Respondent Williams will be subject to the 

applicable laws and regulations governing the reentry process, and reentry may be conditioned 

upon a number of factors, including, but not limited to, the satisfaction of any or all of the 

following:  (a) any disgorgement ordered against the Respondent, whether or not the Commission 

has fully or partially waived payment of such disgorgement; (b) any arbitration award related to the 

conduct that served as the basis for the Commission order; (c) any self-regulatory organization 

arbitration award to a customer, whether or not related to the conduct that served as the basis for 

the Commission order; and (d) any restitution order by a self-regulatory organization, whether or 

not related to the conduct that served as the basis for the Commission order. 

 

 D. Respondent Williams shall, within 10 days of the entry of this Order, pay 

disgorgement of $94,191, prejudgment interest of $9,854, and a civil money penalty in the amount 

of $94,191 to the Securities and Exchange Commission.  If timely payment of disgorgement and 

prejudgment interest is not made, additional interest shall accrue pursuant to SEC Rule of Practice 

600.  If timely payment of the civil money penalty is not made, additional interest shall accrue 

pursuant 31 U.S.C. § 3717.  Payment must be made in one of the following ways:   

 

(1) Respondent may transmit payment electronically to the Commission, which 

will provide detailed ACH transfer/Fedwire instructions upon request;  

 

(2) Respondent may make direct payment from a bank account via Pay.gov 

through the SEC website at http://www.sec.gov/about/offices/ofm.htm; or  

 

(3) Respondent may pay by certified check, bank cashier’s check, or United 

States postal money order, made payable to the Securities and Exchange 

Commission and hand-delivered or mailed to:  

 

Enterprise Services Center 

Accounts Receivable Branch 

HQ Bldg., Room 181, AMZ-341 

6500 South MacArthur Boulevard 

Oklahoma City, OK 73169 

 



 7 

Payments by check or money order must be accompanied by a cover letter identifying 

Williams as the Respondent in these proceedings, and the file number of these proceedings; a copy 

of the cover letter and check or money order must be sent to G. Jeffrey Boujoukos, Associate 

Regional Director, Philadelphia Regional Office, Securities and Exchange Commission, 1617 JFK 

Boulevard, Suite 520, Philadelphia, PA 19103.   

 

 E.  Pursuant to Section 308(a) of the Sarbanes-Oxley Act of 2002, as amended, a Fair 

Fund is created for the disgorgement, interest and civil money penalty referenced in paragraph D 

above.  The disgorgement, interest and civil money penalty referenced in paragraph D above shall 

be distributed through a Fair Fund established in a related administrative proceeding arising out of 

the same underlying facts.  Amounts ordered to be paid as civil money penalties pursuant to this 

Order shall be treated as penalties paid to the government for all purposes, including all tax 

purposes.  To preserve the deterrent effect of the civil penalty, Respondent agrees that in any 

Related Investor Action, he shall not argue that he is entitled to, nor shall he benefit by, offset or 

reduction of any award of compensatory damages by the amount of any part of Respondent’s 

payment of a civil penalty in this action (“Penalty Offset”).  If the court in any Related Investor 

Action grants such a Penalty Offset, Respondent agrees that he shall, within 30 days after entry of 

a final order granting the Penalty Offset, notify the Commission’s counsel in this action and pay 

the amount of the Penalty Offset to the Securities and Exchange Commission.  Such a payment 

shall not be deemed an additional civil penalty and shall not be deemed to change the amount of 

the civil penalty imposed in this proceeding.  For purposes of this paragraph, a “Related Investor 

Action” means a private damages action brought against Respondent by or on behalf of one or 

more investors based on substantially the same facts as alleged in the Order instituted by the 

Commission in this proceeding. 

  

V. 

It is further Ordered that, solely for purposes of exceptions to discharge set forth in Section 

523 of the Bankruptcy Code, 11 U.S.C. § 523, the findings in this Order are true and admitted by 

Respondent, and further, any debt for disgorgement, prejudgment interest, civil penalty or other 

amounts due by Respondent under this Order or any other judgment, order, consent order, decree  

  



 8 

or settlement agreement entered in connection with this proceeding, is a debt for the violation by 

Respondent of the federal securities laws or any regulation or order issued under such laws, as set 

forth in Section 523(a)(19) of the Bankruptcy Code, 11 U.S.C. § 523(a)(19). 

 

 

 By the Commission.  

 

 

 

       Brent J. Fields 

       Secretary