Articles Posted in Reg BI

According to records kept by The Financial Industry Regulatory Authority (FINRA) financial Broker Ashish Aggarwal (Aggarwal), previously associated with J.P. Morgan Securities LLC, has at least one disclosable event. These events include one tax lien, alleging that Aggarwal recommended unsuitable investments in different investment products including debt securities among other allegations and complaints.

FINRA BrokerCheck shows a final customer complaint on February 05, 2025.

The Securities and Exchange Commission (‘Commission’) deems it appropriate and in the public interest that public administrative proceedings be, and hereby are, instituted against Ashish Aggarwal (‘Respondent’). In anticipation of the institution of these proceedings, Respondent has submitted an Offer of Settlement which the Commission has determined to accept. The commission finds that on February 3, 2025, a final judgment was entered by consent against Aggarwal, permanently enjoining him from future violations of Sections 10(b) and 14(e) of the Exchange Act and Rules 10b-5 and 14e-3 thereunder, as set forth in the judgment entered in the civil action entitled Securities and Exchange Commission v. Ashish Aggarwal, et al., Civil Action Number 2:15-cv 06460, in the United States District Court for the Central District of California. The Commission’s complaint alleged that Aggarwal engaged in insider trading in the securities of PLX Technology, Inc. (‘PLX’) in 2012 and ExactTarget, Inc. (‘ExactTarget’) in 2013. Specifically, the Commission alleged that Aggarwal, then an investment banking analyst at JPMS, obtained illicit profits by recommending ExactTarget to a friend during a period in which JPMS played an advisory role in a tender offer transaction that entailed the purchase of the outstanding shares of ExactTarget by salesforce.com. In addition, the Commission alleged that Aggarwal tipped another friend, Shahriyar Bolandian, with material non-public information regarding the ExactTarget-salesforce.com transaction and an earlier impending tender offer transaction in which JPMS played an advisory role, the proposed purchase of the outstanding shares of PLX by Integrated Device Technology, Inc. Bolandian, as alleged, then provided the information to his work colleague and friend, Kevan Sadigh. Both Bolandian and Sadigh, acting largely in parallel, bought securities of PLX and ExactTarget on the basis of the material nonpublic information, leading to illicit profits for themselves and in the accounts of Bolandian’s family members.

According to records kept by The Financial Industry Regulatory Authority (FINRA) financial Broker Roger Gallagher (Gallagher), previously associated with Morgan Stanley, has at least one disclosable event. These events include one tax lien, alleging that Gallagher recommended unsuitable investments in different investment products including debt securities among other allegations and complaints.

FINRA BrokerCheck shows a final customer complaint on February 19, 2025.

Without admitting or denying the findings, Gallagher consented to the sanction and to the entry of findings that he refused to provide documents and information and to appear for on-the-record testimony requested by FINRA in connection with an investigation concerning, among other things, the allegations in a criminal indictment filed against him.

According to records kept by The Financial Industry Regulatory Authority (FINRA) financial Broker Ruben Trujillo (Trujillo), previously associated with Wells Fargo Clearing Services, LLC, has at least one disclosable event. These events include one tax lien, alleging that Trujillo recommended unsuitable investments in different investment products including debt securities among other allegations and complaints.

FINRA BrokerCheck shows a final customer complaint on February 07, 2025.

Respondent Trujillo failed to comply with an arbitration award or settlement agreement or to satisfactorily respond to a FINRA request to provide information concerning the status of compliance.

According to records kept by The Financial Industry Regulatory Authority (FINRA) financial Broker John Hoile (Hoile), currently associated with Wells Fargo Clearing Services, LLC, has at least 2 disclosable events. These events include 2 customer complaints, alleging that Hoile recommended unsuitable investments in different investment products including debt securities among other allegations and complaints.

FINRA BrokerCheck shows a settled customer complaint on February 06, 2025.

Claimant alleges REIT purchased was unsuitable.

According to records kept by The Financial Industry Regulatory Authority (FINRA) financial Broker Michael Shaughnessy (Shaughnessy), previously associated with MML Investors Services, LLC, has at least one disclosable event. These events include one customer complaint, alleging that Shaughnessy recommended unsuitable investments in different investment products including debt securities among other allegations and complaints.

FINRA BrokerCheck shows a pending customer complaint on February 05, 2025.

The complainant alleges that the Annuity she purchased in/and around April 2020, was misrepresented by her registered representative, and told her the annuity would never earn less, and would only go up in value. The complainant also states that there was never any mention of a minimum percentage and was expecting to earn 15-20%.

According to records kept by The Financial Industry Regulatory Authority (FINRA) financial Broker Sharif Sharif (Sharif), previously associated with LPL Financial LLC, has at least 2 disclosable events. These events include 2 tax liens, alleging that Sharif recommended unsuitable investments in different investment products including debt securities among other allegations and complaints.

FINRA BrokerCheck shows a pending customer complaint on February 02, 2025.

While registered as an investment advisor in the state of Illinois, Sharif Azmi Sharif entered into a Letter of Acceptance, Waiver and Consent (“AWC”) with FINRA a self-regulatory organization registered under Federal Act. Pursuant to AWC No. 2022076175701, on June 11, 2024. Sharif Sharif violated Rules 3280 and Rule 2010, based upon the following facts. Sharif Sharif was a founding investor and employee in a crypto asset mining company. In February, 2022, he and his partner Azmi Sharif held a meeting with LPL customers concerning investment in the company. Both investors and investor family members collectively invested approximately $900,000 in securities known as SAFEs (simple agreements for future equity). The investments were, among other things, the purchase of crypto asset mining equipment. LPL was notified of the transaction. The FINRA AWC resulted in a nine month suspension from associating with any FINRA member in all capacities. The current action seeks revocation in Illinois based upon the FINRA AWC.

According to records kept by The Financial Industry Regulatory Authority (FINRA) financial Broker Todd Luft (Luft), previously associated with B. Riley Wealth Management, has at least one disclosable event. These events include one tax lien, alleging that Luft recommended unsuitable investments in different investment products including debt securities among other allegations and complaints.

FINRA BrokerCheck shows a final customer complaint on February 19, 2025.

Respondent Luft failed to comply with an arbitration award or settlement agreement or to satisfactorily respond to a FINRA request to provide information concerning the status of compliance.

According to records kept by The Financial Industry Regulatory Authority (FINRA) financial Broker Michael Hamilton (Hamilton), currently associated with Centaurus Financial, Inc., has at least one disclosable event. These events include one tax lien, alleging that Hamilton recommended unsuitable investments in different investment products including debt securities among other allegations and complaints.

FINRA BrokerCheck shows a final customer complaint on February 07, 2025.

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 against Centaurus Financial, Inc. (‘Centaurus’), Debbie M. Cavanaugh (‘Cavanaugh’), Michael Y. Hamilton (‘Hamilton’), Dana Matthew Hawkins (‘Hawkins’), and Timothy N. Tremblay (‘Tremblay’) (collectively, the ‘Respondents’). In anticipation of the institution of these proceedings, Respondents have submitted Offers of Settlement (‘Offers’) which the Commission has determined to accept. On the basis of this Order and Respondents’ Offers, the Commission finds that: Between June 30, 2020, the compliance date for Regulation Best Interest (‘Regulation BI’), and approximately April 16, 2021 (the ‘Relevant Period’), Respondents did not comply with Regulation BI in connection with their recommendations of corporate bonds called ‘L Bonds’ offered by GWG Holdings, Inc. (‘GWG’) to certain retail customers. According to GWG’s disclosures during the Relevant Period: (a) L Bond investments involved a high degree of risk, including the risk of losing an investor’s entire investment; (b) L Bond investments May be considered speculative; (c) L Bond investments were only suitable for investors with substantial financial resources and no need for liquidity in the investment; and (d) GWG May use a portion of the L Bond proceeds to repay existing L Bond holders. Despite these disclosures, Centaurus and its registered representatives – Respondents Cavanaugh, Hamilton, Hawkins and Tremblay, recommended the purchase of L Bonds to 18 retail customers for whom Respondents did not have a reasonable basis to believe that the recommendations were in those customers’ best interest based on those customers’ investment profiles and the potential risks, rewards, and costs associated with the L Bonds. As a result, Centaurus, Cavanaugh, Hamilton, Hawkins and Tremblay did not comply with the Customer-Specific Prong of Regulation BI’s Care Obligation found in Exchange Act Rule 15l-1(a)(2)(ii)(B). Centaurus also did not reasonably enforce its own written policies and procedures requiring personnel to take training related to Regulation BI and training related to a 2020 Offering of GWG L Bonds. As a result, Centaurus did not comply with Regulation BI’s Compliance Obligation found in Exchange Act Rule 15l-1(a)(2)(iv). By not complying with these Regulation BI component obligations, the Respondents each willfully violated Regulation BI’s General Obligation found in Exchange Act Rule 15l-1(a)(1).

According to records kept by The Financial Industry Regulatory Authority (FINRA) financial Broker Debbie Cavanaugh (Cavanaugh), currently associated with Centaurus Financial, Inc., has at least one disclosable event. These events include one tax lien, alleging that Cavanaugh recommended unsuitable investments in different investment products including debt securities among other allegations and complaints.

FINRA BrokerCheck shows a final customer complaint on February 07, 2025.

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 against Centaurus Financial, Inc. (‘Centaurus’), Debbie M. Cavanaugh (‘Cavanaugh’), Michael Y. Hamilton (‘Hamilton’), Dana Matthew Hawkins (‘Hawkins’), and Timothy N. Tremblay (‘Tremblay’) (collectively, the ‘Respondents’). In anticipation of the institution of these proceedings, Respondents have submitted Offers of Settlement (‘Offers’) which the Commission has determined to accept. On the basis of this Order and Respondents’ Offers, the Commission finds that: Between June 30, 2020, the compliance date for Regulation Best Interest (‘Regulation BI’), and approximately April 16, 2021 (the ‘Relevant Period’), Respondents did not comply with Regulation BI in connection with their recommendations of corporate bonds called ‘L Bonds’ offered by GWG Holdings, Inc. (‘GWG’) to certain retail customers. According to GWG’s disclosures during the Relevant Period: (a) L Bond investments involved a high degree of risk, including the risk of losing an investor’s entire investment; (b) L Bond investments May be considered speculative; (c) L Bond investments were only suitable for investors with substantial financial resources and no need for liquidity in the investment; and (d) GWG May use a portion of the L Bond proceeds to repay existing L Bond holders. Despite these disclosures, Centaurus and its registered representatives – Respondents Cavanaugh, Hamilton, Hawkins and Tremblay, recommended the purchase of L Bonds to 18 retail customers for whom Respondents did not have a reasonable basis to believe that the recommendations were in those customers’ best interest based on those customers’ investment profiles and the potential risks, rewards, and costs associated with the L Bonds. As a result, Centaurus, Cavanaugh, Hamilton, Hawkins and Tremblay did not comply with the Customer-Specific Prong of Regulation BI’s Care Obligation found in Exchange Act Rule 15l-1(a)(2)(ii)(B). Centaurus also did not reasonably enforce its own written policies and procedures requiring personnel to take training related to Regulation BI and training related to a 2020 Offering of GWG L Bonds. As a result, Centaurus did not comply with Regulation BI’s Compliance Obligation found in Exchange Act Rule 15l-1(a)(2)(iv). By not complying with these Regulation BI component obligations, the Respondents each willfully violated Regulation BI’s General Obligation found in Exchange Act Rule 15l-1(a)(1).

According to records kept by The Financial Industry Regulatory Authority (FINRA) financial Broker Timothy Tremblay (Tremblay), currently associated with Centaurus Financial, Inc., has at least 4 disclosable events. These events include 3 customer complaints, one tax lien, alleging that Tremblay recommended unsuitable investments in different investment products including debt securities among other allegations and complaints.

FINRA BrokerCheck shows a final customer complaint on February 07, 2025.

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 against Centaurus Financial, Inc. (‘Centaurus’), Debbie M. Cavanaugh (‘Cavanaugh’), Michael Y. Hamilton (‘Hamilton’), Dana Matthew Hawkins (‘Hawkins’), and Timothy N. Tremblay (‘Tremblay’) (collectively, the ‘Respondents’). In anticipation of the institution of these proceedings, Respondents have submitted Offers of Settlement (‘Offers’) which the Commission has determined to accept. On the basis of this Order and Respondents’ Offers, the Commission finds that: Between June 30, 2020, the compliance date for Regulation Best Interest (‘Regulation BI’), and approximately April 16, 2021 (the ‘Relevant Period’), Respondents did not comply with Regulation BI in connection with their recommendations of corporate bonds called ‘L Bonds’ offered by GWG Holdings, Inc. (‘GWG’) to certain retail customers. According to GWG’s disclosures during the Relevant Period: (a) L Bond investments involved a high degree of risk, including the risk of losing an investor’s entire investment; (b) L Bond investments May be considered speculative; (c) L Bond investments were only suitable for investors with substantial financial resources and no need for liquidity in the investment; and (d) GWG May use a portion of the L Bond proceeds to repay existing L Bond holders. Despite these disclosures, Centaurus and its registered representatives – Respondents Cavanaugh, Hamilton, Hawkins and Tremblay, recommended the purchase of L Bonds to 18 retail customers for whom Respondents did not have a reasonable basis to believe that the recommendations were in those customers’ best interest based on those customers’ investment profiles and the potential risks, rewards, and costs associated with the L Bonds. As a result, Centaurus, Cavanaugh, Hamilton, Hawkins and Tremblay did not comply with the Customer-Specific Prong of Regulation BI’s Care Obligation found in Exchange Act Rule 15l-1(a)(2)(ii)(B). Centaurus also did not reasonably enforce its own written policies and procedures requiring personnel to take training related to Regulation BI and training related to a 2020 Offering of GWG L Bonds. As a result, Centaurus did not comply with Regulation BI’s Compliance Obligation found in Exchange Act Rule 15l-1(a)(2)(iv). By not complying with these Regulation BI component obligations, the Respondents each willfully violated Regulation BI’s General Obligation found in Exchange Act Rule 15l-1(a)(1).

Contact Information