FINRA has fined two former Columbia Capital Securities brokers $10,000 each and suspended them for 10 months over undisclosed private securities transactions tied to an offering that raised about $8 million from 18 investors. Josiah Jennings of Yorba Linda, California, and William Pugh of Los Angeles accepted the sanctions in disciplinary actions filed in August 2026.
What happened
Josiah Jennings (CRD# 6031164) and William Pugh (CRD# 4855771) participated in an outside securities offering while registered with Columbia Capital Securities. FINRA rules required both brokers to give their firm prior written notice before taking part in any private securities transaction. Neither broker did.
The offering raised approximately $8 million from 18 accredited investors, according to FINRA documents. Nearly all of those investors were Columbia Capital customers who had earlier bought equity interests in the same fund.
Inside the $8 million offering
FINRA’s findings describe an active role for Jennings. He helped draft the offering documents, selected which investors the fund would approach, joined the initial outreach meetings, and executed promissory notes on the fund’s behalf.
Pugh also participated without providing the written notice his firm was entitled to receive. Regulators call the pattern selling away, and it strips the brokerage firm of any chance to supervise the deal.
The offering by the numbers
| Measure | Figure |
|---|---|
| Total raised | About $8 million |
| Investors | 18 accredited investors |
| Average investment | About $444,000 per investor |
| Investor source | Nearly all Columbia Capital customers |
| Instrument | Promissory notes and equity interests |
An average commitment near $444,000 per investor marks this as a serious exposure for the households involved, not a token allocation. Those who bought equity interests in the fund before the promissory notes were solicited again.
Sanctions against Jennings and Pugh
| Broker | CRD# | AWC number | Fine | Suspension |
|---|---|---|---|---|
| Josiah Jennings | 6031164 | No. 2024083338801 | $10,000 | 10 months, all capacities |
| William Pugh | 4855771 | No. 2024083338701 | $10,000 | 10 months, all capacities |
Both brokers settled through Letters of Acceptance, Waiver, and Consent without admitting or denying the findings. The suspensions bar each man from associating with any FINRA member firm in any capacity for 10 months.
Why firm notification matters
Brokerage firms run supervision programs that review outside business activity for conflicts, suitability, and disclosure problems. When a broker sells interests in an outside fund to his own customers, none of that review ever happens.
The customers bear the risk. They trusted a regulated adviser and ended up holding a position the firm never examined.
Registration history
Jennings left Columbia Capital Securities and is currently registered as an investment adviser with Vela Consulting. Pugh was most recently registered as a broker with Columbia Capital Securities. Both records remain available through FINRA BrokerCheck.
What investors should do now
Private placements are illiquid, and exit options are limited once the money is committed. If a broker sold you an outside offering without disclosing his own role in it, request every document you signed, including subscription agreements and promissory notes.
Compare what you were told against the written disclosures. Gaps between the pitch and the paperwork are the kind of evidence arbitration panels weigh.
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This article is for informational purposes only and does not constitute legal advice.
You can also read Private Placement Fraud: How Unregistered Securities Harm Retail Investors and Sung Moo Cho Barred by FINRA Over $3.5 Million Broker Misappropriation.
