Securities Lawyers Blog
According to records kept by The Financial Industry Regulatory Authority (FINRA) financial Broker Patrick Perugino (Perugino), currently associated with Craft Capital Management LLC, has at least 2 disclosable events. These events include one customer complaint, one regulatory event, alleging that Perugino recommended unsuitable investments in different investment products including debt securities among other allegations and complaints.
FINRA BrokerCheck shows a final customer complaint on December 05, 2022.
Without admitting or denying the findings, Perugino consented to the sanctions and to the entry of findings that he exercised discretion in customer accounts to effect trades without prior written authorization from the customers and without his member firms having accepted the accounts as discretionary in writing. The findings stated that for one of the customers, Perugino exercised discretion in placing a trade in the customer’s account while Perugino was associated with one of his firms. With respect to the other customers, Perugino engaged in discretionary trading by placing numerous trades in their accounts while these accounts were at his other firms. Although one of the firm’s WSPs permitted discretionary accounts, Perugino did not follow the firm’s procedures to obtain written authorization from the customers or seek approval from the firm to maintain any discretionary accounts at the firm. Instead, Perugino failed to disclose the discretionary trading, incorrectly marking on two firm annual attestations that he did not handle any customer accounts on a discretionary basis.