~ pennsylvania 

• DEPARTMENT OF BANKI NG 

AND SECURITIES 

CERTIFICATION 

Name of Requester: Raynalda N. Milord, Senior Paralegal Specialist 

U.S. Securities and Exchange Commission 

Miami Regional Office 

801 Brickell Avenue, Suite 1950 

Miami, FL 33131 

Records Requested: Ce1tified copy of Final Order and attached Consent Agreement 

and Order in the matter of: 

Dean J. Vagnozzi d/b/a A Better Financial Plan, LLC 

Docket No. 190016 (SEC-CAO) 

I, Linnea Freeberg, hereby declare under the penalty of 108 Pa.C.S. § 4904, that the following 

statements are true and correct based upon my personal knowledge, information and belief: 

1. I serve as the Docket Clerk for the Department of Banking and Securities ("Agency"). 

2. I am custodian of files related to administrative proceedings at the Agency. 

3. In my capacity as Docket Clerk, I am familiar with the records of the Agency. 

4. Upon receipt of the request, I conducted a thorough examination of files in the 

possession, custody and control of the Agency for records responsive to the request. 

5. After conducting a good faith search of the Agency's files, I identified all records within 

the Agency's possession, custody or control that are responsive to the request. 

6. The Agency records identified as responsive to the request are attached to this 

ce1tification. 

7. I ce1tify that the attached documents are a complete and true copy of the original 

responsive records. 

Date: Ce (~[ZoZo Signature: 

Linnea Freeberg, Docket Clerk 

Depaitment of Banking and Securities 

Case 9:20-cv-81205-RAR Document 24-8 Entered on FLSD Docket 07/27/2020 Page 1 of 8
COMMONWEALTH OFPENNSYLVANIA 1nj , BANKING AND SECURITIES COMMISSION" g tl,H 30 All 9: 08 

COMMONWEALTH OF PENNSYLVANIA 

DEPARTMENT OF BANKING AND 

SECURITIES, BUREAU OF SECURITIES 

COMPLIANCE AND EXAMINATIONS Docket No.: 190016 (SEC-OSC) 

v. 

DEAN J. V AGNOZZI d/b/a 

A BETTER FINANCIAL PLAN, LLC 

FINAL ORDER 

~ 

NOW, this~ day of May 2019, the Pennsylvania Banking and Securities Commission 

("Commission") has reviewed the attached Consent Agreement and Order ("CAO") executed by 

the pa1iies in the above-captioned matter now pending before a hearing officer designated by the 

Secretary of Banking and Securities. The Commission APPROVES the CAO pursuant to the final 

adjudication authority granted it under Section 1122-A.(1) of the Department of Banking and 

Securities Code, 71 P.S. § 733-1 J 22-A.(l ). In the CAO, Dean J. Vagnozzi d/b/a A Better Financial 

Plan, LLC agrees, among other things, to resolve the matter by paying an administrative 

assessment in the amount of $490,000.00. 

BY ORDER OF THE COMMISSION: 

Redacted 

.James R. Biery 

Chair 

Pennsylvania Banking and Securities Commission 

Case 9:20-cv-81205-RAR Document 24-8 Entered on FLSD Docket 07/27/2020 Page 2 of 8
COMMONWEALTH OF PENNSYLVANIA 

DEPARTMENT OF BANICTNG AND SECURITIES 

2019 M,W 30 All 9: 08 

COMMONWEALTH OF PENNSYLVANIA 

DEPARTMENT OF BANIONG AND 

SECURITIES, BUREAU OF SECURITIES 

COMPLIANCE AND EXAMINATIONS Docket No, : 190016 (SEC~CAO) 

V, 

DEAN J, VAGNOZZI d/b/a 

A BETTER FINANCIAL PLAN, LLC 

CONSENT AGREEMENT AND ORDER 

The Commonwealth of Pennsylvania, acting through the Depattment of Banking and Sec\lrities 

("Department"), Bureau of Securities Compliance and Examinations ("Bureaull), has conducted an 

investigation of the role of Dean J, Vagnozzl d/6/a A Better Financial Plan, LLC CVagnozzi") in 

conneotion with the sale of notes offered and sold by Complete Business Solutions Group, Inc. d/6/a 

PAR Funding ("CBSG,,) from in or about August 2016 through December 2017, Based on the results 

of its investigation, the Bureau has concluded that Vagnozzi has opel'ated in violation of the 

Pennsylvania Securities Act of 1972, 70 P,S. § ]wl0l, et. seq. (''1972 Act"), Vagnozzi, in lieu of 

litigation, and without admitting or denying the allegations contained hel'ein, and intendmg to be legally 

bound, hereby agrees to the entry of this Consent Ag1eement and Ol'der C'CA011), 

BACKGROUND 

1. The Depattment is the Commonwealth of Pe1msylvania's administrative agency 

authol'ized and empowered to administer and enforce the 1972 Act. 

2. The Bmeau ls primarily iesponsible fm administel'ing and enforomg the 1972 

Act for the Depal'tment. 

Case 9:20-cv-81205-RAR Document 24-8 Entered on FLSD Docket 07/27/2020 Page 3 of 8
3. The BU1'eat1 operates from the Departmenfs main office located at 17 North 

Second Streeti Suite 1300, Hardsburg, Pennsylvania 17101, 

4. Respondent Vugnozzl (CRD #5490000) was, at all material times herein, an 

Individual with addresses at Redact~d and 234 Mat! 

Bouleva1·d, Suite 270, King of Prussia, Pennsylvania 19406. 

5. From 011 or about August 2016 th1'ough December 2017, Vagnozzi effected 

the sale of NonwNegotiable Tenn Promissory Notes (

11Notes 11) issued by CBSG to at least 

one Pennsylvania resident, 

6. Vagnozzi received compensation f1om CBSG for the sale of the Notes 

issued by CBSG. 

7. Vagnozzi was neither registered as an "agene• pUl'suant to Section 301 (a) of 

the 1972 Act, 70 P ,S, § l w301 (a), not· exempt from t·egistt·ation, 

VIOLATION 

8. By engaging in the acts and conduct set forth in paragraph 5 through 7 above, 

Vagnozzi effected transactions in securities in Pennsylvania while neither 1egistered no1· 

exempt from 1eglstration as an "agent" in willful violation of Section 301 (a) of the 1972 Act1 

70 P.S, § l-30l(a). 

RELIEF 

9. Vagnozzi shall pay the Department an administrative assessment in the 

amount of $490,000. Payment shall be made simultaneously wlth the submission by 

Vagnozzi of this CAO by certified check or money orde1· that is made payable to the 

Department of Banking and Securities and shall be mailed 01• delivered, in person, to the 

Bu1·eau of Securities Compliance and Examinations located at 17 N, Second Stl'eet, Suite 

1300) Hanisburgi PA 17101, 

Case 9:20-cv-81205-RAR Document 24-8 Entered on FLSD Docket 07/27/2020 Page 4 of 8
10. Vagnozzi shall comply with the 1972 Act and Regulations adopted by the 

Depaitment, and in particular Section 301 (a) of the 1972 Act, 70 P.S. § 1~301 (a), et. seq. 

11. Should Vagnozzi fail to comply with any or all pl'ovisions of this Order, the 

Department may impose additional sanctions and costs and seek other appropriate relief 

subject to the right to a hearing pursuant to the 1972 Act 

12, This Order is not intended to indicate that Vagnozzi or any of hls affiliates or 

cu1 tent of fonner employees should be subject to any disqualification contained in the federal 

secmities laws, the t ules and regulations thereunder; the rules and regulations of self" 

regulatory organizations or various states' securities law, including the provisions of the 

1972 Act and regulations promulgated thereunder; and any disqualification from relying 

upon the registration exemptions 01· safe harbor provis\ons, and this Order is not intended to 

form the basis of any such disqualification. 

FURTHER PROVISIONS 

13, Consent. Vagnozzl hereby knowingly, willingly, voluntal'ily and irrevocably 

consents to the ent1y of this Order pursuant to the Bureau's authority under the 1972 Act and 

ag1ees he understands all of the terms and conditions contained herein. Vagnozzi, by 

voluntarily entering into this Order, has elected not to litigate or contest the allegations 

assei'ted by the Brneau and waives any right to a hearing or appeal concerning the terms, 

conditions and/or penalties set forth in this Order, 

14. Entire Agreement. This Ordet' contains the entire agt·eernent between the 

Depai trnent and Vagnozzi. There are no other terms, obligations, covenants, representations, 

statements, conditions, 01· otherwise, of any kind whatsoever concerning this Order. This 

Order may be amended in writing by mutual agreement by the Department and Vagnozzi. 

Case 9:20-cv-81205-RAR Document 24-8 Entered on FLSD Docket 07/27/2020 Page 5 of 8
15. Binding Nature. The Depnl'tment> Vagnozzi, and all officers, ow11el's, 

dil'ectors, employees, heil's and assigns of Vagnozzi intend to be and are legally bound by 

the terms of this Order, 

16, Counsel. This Order is entered into by the parties upon full opportunity for 

legal advice from legal counsel. 

17. Effectiveness, Pursuant to the final adjudication authority granted to the 

Banking and Securities Commission (uCommissionu) under Section 1122-A(l) of the 

Department of Banldng and Securities Code, 71 P.S. § 733-1122-A(l)> the CAO becomes 

effective upon the Commission's issuance of an order approving the CAO. 

18, Other Enforcement Action, 

a. The Department reserves all of its rights, duties, ancl authority to 

enforce all statutes> 1 ules and regulations under its jurisdiction against 

Vagnozzi in the future regarding all matters not resolved by this 

Order. 

b, Vagnozzi aclmowledges and agrees that this Ol'del' is only binding 

upon the Department and not any other local, state 01 fedeial agency, 

department or office iegarding matte1s within this 01de1. 

c, Vagnozzi acknowledges and ag1ees that this Ol'der does not preclude 

any other agency from instituting administrative, civil 01 criminal 

proceedings that may be 1elated to matters addressed by this Orde1, 

19. Authorization The parties below are authorized to execute this Order and 

legally blnd their respective parties, 

20, Counterparts. This Order may be executed in separate counterparts, by 

facshrnle and by PDF. 

21. Titles The titles used to identify the paragrnphs of this document are for the 

convenience of reference only and do not control the interpretation of this document. 

Case 9:20-cv-81205-RAR Document 24-8 Entered on FLSD Docket 07/27/2020 Page 6 of 8
22 Finding. The Department finds that it is necessary and appl'opriate in the 

public i11te1·est and for the protection of Investors, imd consistent with the purposes fairly 

intended by the policy and provisions of the l 972 Act to issue this Ol'der, 

WHEREFORE, in consideration of the fo1egolng, including the recital pal'agraphs, 

the Commot1woalth of Pennsylvania, Department of Banking and Seculitles, Bureau of 

Securlties Compliance and Examinations and Dean J, Vagnozzi d/b/a A Better Financial 

Plan, LLC, intending to be legally bound, do hereby execute this Consent Ag1 eement and 

Order, 

FOR THE COMMONWEALTH OF PENNSYLVANIA 

DEPARTMENT OF BANKlNG AND SECURITIES, 

BUREAU OF SECURITIES 

COMPLIANCE AND EXAMINATIONS 

Redacted 

De ecurlties 

Date: --'--~-.,___( 

DEAN ,T, VAGNOZZI d/b/a 

,--A--BEJ:TER FINANCIAL ~N, LLC 

Redacted 

Date: 

Case 9:20-cv-81205-RAR Document 24-8 Entered on FLSD Docket 07/27/2020 Page 7 of 8
COMMONWEALTH OF PENNSYLVANIA 

BANKING AND SECURITIES COMMISSION2019 M,\Y 20 Al1 9: 08 

COMMONWEAL TH OF PENNSYLVANIA 

DEPARTMENT OF BANKING AND 

SECURITIES, BUREAU OF SECURITIES 

COMPLIANCE AND EXAMINATIONS 

v. 

DEAN J. V AGNOZZI d/b/a 

A BETTER FINANCIAL PLAN, LLC 

Docket No.: 190016 (SEC-OSC) 

CERTIFICATE OF SERVICE 

On behalf of the agency, I ce1tify that I have this day caused to be served a copy of the 

f01egoing Final Order upon the following persons pmsuant to 1 Pa. Code§§ 33.31: 

BY CERTIFIED AND 

FIRST CLASS MAIL: 

John W. Pauciulo, Esquire 

Ecke1t Seamans Cherin & Mellott, LLC 

Two Liberty Place, 22nd Floor 

50 South 16th Street 

Philadelphia, PA 19102 

';_/\~ 

Dated thiS---_7__;_ day of May 2019 

BY ELECTRONIC MAIL: 

John Chiappetta, Assistant Counsel 

Commonwealth of Pennsylvania 

Depaitment of Banking and Securities 

17 North Second Street, Suite 1300 

Harrisburg, PA 17101 

Counsel for the Bureau of Securities 

Compliance and Examinations 

Redacted 

Jj1~~ea Freeberg, Docket derk 

PA Banking and Securities Commission 

17 N. 2nd Street, Suite 1300 

Harrisburg, PA 17101 

Telephone: (717) 787-5783 

Case 9:20-cv-81205-RAR Document 24-8 Entered on FLSD Docket 07/27/2020 Page 8 of 8