Securities Lawyers Blog

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).