Weekly Enforcement Action Tracker (May 31 – June 8)

Penalties: N/A
Respondent: Jaron C. Lester
Violation: The Commissioner being fully advised, now hereby notifies Applicant that he has not fully met the requirements of licensure as stated by Indiana Code 27-1-15.6-12(b)(8) due to the 2016 revocation of his Missouri teaching certificate and surrounding circumstances… Read More

Penalties: N/A
Respondent: Robert Moir
Violation: The Commissioner of Insurance hereby notifies Respondent that his license shall not be renewed due to violating an order of the Commissioner… Read More

Penalties: N/A
Respondent: Shawn H. Nazario
Violation: Applicant’s Indiana nonresident producer license shall be granted and Applicant shall be placed on probation for 2 years, during which time any violations of Title 27 will result in the Department seeking immediate revocation of Applicant’s license… Read More

Penalties: N/A
Respondent: Joe A. Murello
Violation: Respondents Indiana bail agent license shall be revoked for 1 year after the signing of this Final Order, for failing to pay $29,812.50 in owned premiums… Read More

Penalties: N/A
Respondent: Jack F. Trudeau
Violation: Applicant’s request for licensure is hereby DENIED pursuant to Indiana Code 27-1-15.6-12(b)(8) for having been convicted of Intimidation, a Class A Misdemeanor and having been convicted of Operating a Vehicle While Intoxicated Endangering a Person, a Class A Misdemeanor… Read More

Penalties: N/A
Respondent: Brittany Fry
Violation: Applicant’s license shall be granted and Applicant placed on probation for a period of 2 years beginning upon execution of this Final Order… Read More

Penalties: N/A
Respondent: Kamilah Smith
Violation: Applicant’s request for licensure is hereby DENIED pursuant to Indiana Code 27-1-15.6-12(b)… Read More

Penalties: $586,000,000.00
Respondent: Western Union
Violation: Scammers contacted people and promised prizes, loans, jobs, discounted products or other financial rewards in exchange for money upfront. They also pretended to be family members in need of cash or law enforcement officers demanding payment. The scammers told people to send money through Western Union. No one received the cash, prizes or services they were promised. Western Union was charged with aiding and abetting wire fraud… Read More

Penalties: N/A
Respondent: George Doumanis
Violation: On December 1, 2017, Doumanis pled guilty to one count of conspiracy to commit securities fraud in violation of 18 U.S.C. § 371, before the United States District Court for the Southern District of New York, in United States v. George Doumanis, No. 17-Cr. 087 (ALC)… Read More

Penalties: TBD
Respondent: Woojae (Steve) Jung
Violation: Between 2015 and 2017, Jung used an account held in the name of a friend living in South Korea to place these illegal trades and generate profits of approximately $140,000. As alleged in the complaint, by using his friend’s brokerage account, Jung attempted to evade detection by skirting his employer’s requirements that he pre-clear his trades and that he uses an approved brokerage firm that would have reported the trading to his employer… Read More

Penalties: N/A
Respondent: SEC Complaint – Woojae (Steve) Jung
Violation: Jung obtained access to sensitive information about impending transactions in which the Investment Bank was advising one of the parties. Between at least February 2015 and July 2017, Jung misappropriated that highly-confidential information to trade in the securities of 12 different companies prior to the public announcement of the transactions… Read More

Penalties: $75,000.00
Respondent: Elm Partners Management LLC
Violation: This matter involves Elm’s violations of the reporting provisions of Rule 204(b)-1 under the Advisers Act. Rule 204(b)-1 requires certain investment advisers with at least $150 million in private fund assets under management to file and periodically update a report on Form PF to provide information about the private funds they manage. From 2013 through 2016, Elm was subject to the reporting requirements of Rule 204(b)-1 but failed to file or update a report on Form PF… Read More

Penalties: $75,000.00
Respondent: Bachrach Asset Management Inc.
Violation: This matter involves Bachrach’s violations of the reporting provisions of Rule 204(b)-1 under the Advisers Act. Rule 204(b)-1 requires certain investment advisers with at least $150 million in private fund assets under management to file and periodically update a report on Form PF to provide information about the private funds they manage. From 2012 through 2016, Bachrach was subject to the reporting requirements of Rule 204(b)-1 but failed to file or update a report on Form PF… Read More

Penalties: $75,000.00
Respondent: Ecosystem Investment Partners LLC
Violation: This matter involves Ecosystem’s violations of the reporting provisions of Rule 204(b)-1 under the Advisers Act. Rule 204(b)-1 requires certain investment advisers with at least $150 million in private fund assets under management to file and periodically update a report on Form PF to provide information about the private funds they manage. From 2013 through 2016, Ecosystem was subject to the reporting requirements of Rule 204(b)-1 but failed to file or update a report on Form PF… Read More

Penalties: $75,000.00
Respondent: RLJ Equity Partners, LLC
Violation: This matter involves RLJ’s violations of the reporting provisions of Rule 204(b)-1 under the Advisers Act. Rule 204(b)-1 requires certain investment advisers with at least $150 million in private fund assets under management to file and periodically update a report on Form PF to provide information about the private funds they manage. From 2012 through 2016, RLJ was subject to the reporting requirements of Rule 204(b)-1 but failed to file or update a report on Form PF… Read More

Penalties: $75,000.00
Respondent: Bristol Group, Inc.
Violation: This matter involves Bristol Group Inc.’s violations of the reporting provisions of Rule 204(b)-1 under the Advisers Act. Rule 204(b)-1 requires certain investment advisers with at least $150 million in private fund assets under management to file and periodically update a report on Form PF to provide information about the private funds they manage. From 2013 through 2016, Bristol was subject to the reporting requirements of Rule 204(b)-1 but failed to file or update a report on Form PF… Read More

Penalties: $75,000.00
Respondent: Biglari Capital LLC
Violation: This matter involves Biglari Capital LLC’s violations of the reporting provisions of Rule 204(b)-1 under the Advisers Act. Rule 204(b)-1 requires certain investment advisers with at least $150 million in private fund assets under management to file and periodically update a report on Form PF to provide information about the private funds they manage. From 2013 through 2016, Biglari was subject to the reporting requirements of Rule 204(b)-1 but failed to file or update a report on Form PF… Read More

Penalties: $75,000.00
Respondent: Cherokee Investment Partners LLC
Violation: This matter involves Cherokee’s violations of the reporting provisions of Rule 204(b)-1 under the Advisers Act. Rule 204(b)-1 requires certain investment advisers with at least $150 million in private fund assets under management to file and periodically update a report on Form PF to provide information about the private funds they manage. From 2012 through 2016, Cherokee was subject to the reporting requirements of Rule 204(b)-1 but failed to file or update a report on Form PF… Read More

Penalties: $75,000.00
Respondent: Rose Park Advisors, LLC
Violation: This matter involves Rose Park’s violations of the reporting provisions of Rule 204(b)-1 under the Advisers Act. Rule 204(b)-1 requires certain investment advisers with at least $150 million in private fund assets under management to file and periodically update a report on Form PF to provide information about the private funds they manage. From 2015 through 2016, Rose Park was subject to the reporting requirements of Rule 204(b)-1, but failed to file or update a report on Form PF… Read More

Penalties: $75,000.00
Respondent: CAI Managers & Co., L.P.
Violation: This matter involves CAI Managers & Co., L.P.’s violations of the reporting provisions of Rule 204(b)-1 under the Advisers Act. Rule 204(b)-1 requires certain investment advisers with at least $150 million in private fund assets under management to file and periodically update a report on Form PF to provide information about the private funds they manage. From 2012 through 2016, CAI was subject to the reporting requirements of Rule 204(b)-1, but failed to file or update a report on Form PF… Read More

Penalties: $75,000.00
Respondent: Brahma Management, Ltd.
Violation: This matter involves Brahma Management, Ltd.’s violations of the reporting provisions of Rule 204(b)-1 under the Advisers Act. Rule 204(b)-1 requires certain investment advisers with at least $150 million in private fund assets under management to file and periodically update a report on Form PF to provide information about the private funds they manage. From 2012 through 2016, Brahma was subject to the reporting requirements of Rule 204(b)-1, but failed to file or update a report on Form PF… Read More

Penalties: $75,000.00
Respondent: Prescott General Partners LLC
Violation: This matter involves Prescott’s violations of the reporting provisions of Rule 204(b)-1 under the Advisers Act. Rule 204(b)-1 requires certain investment advisers with at least $150 million in private fund assets under management to file and periodically update a report on Form PF to provide information about the private funds they manage. From 2012 through 2016, Prescott was subject to the reporting requirements of Rule 204(b)-1, but failed to file or update a report on Form PF… Read More

Penalties: $75,000.00
Respondent: HEP Management Corporation
Violation: This matter involves HEP’s violations of the reporting provisions of Rule 204(b)-1 under the Advisers Act. Rule 204(b)-1 requires certain investment advisers with at least $150 million in private fund assets under management to file and periodically update a report on Form PF to provide information about the private funds they manage. From 2013 through 2016, HEP was subject to the reporting requirements of Rule 204(b)-1, but failed to file or update a report on Form PF… Read More

Penalties: $75,000.00
Respondent: Veteri Place Corporation
Violation: This matter involves Veteri Place Corporation’s violations of the reporting provisions of Rule 204(b)-1 under the Advisers Act. Rule 204(b)-1 requires certain investment advisers with at least $150 million in private fund assets under management to file and periodically update a report on Form PF to provide information about the private funds they manage. From 2014 through 2016, Veteri was subject to the reporting requirements of Rule 204(b)-1, but failed to file or update a report on Form PF… Read More

Penalties: N/A
Respondent: SEC Complaint – Ralph T. Iannelli et al.
Violation: This action arises from an $80 million offering fraud perpetrated by securities fraud recidivist Iannelli and his equipment leasing company, Essex… Read More

Penalties: $8,000,000.00
Respondent: Constant Contact, Inc. and Endurance International Group Holdings, Inc.
Violation: Due to an error first identified by Endurance in May 2014, Endurance overstated its subscriber count in its required periodic filings with the Commission from the time of its initial public offering of stock in October 2013 to the filing of its periodic report for the third quarter of the fiscal year 2014 in November 2014… Read More

Penalties: N/A
Respondent: SEC Complaint – Alderson, et al.
Violation: Alderson, the former Chief Executive Officer (“CEO) of Commission-registered investment adviser deVere USA Inc. (“DVU”), and Hamilton, a former DVU Area Manager, defrauded hundreds of clients and prospective clients resident in the United States (“US”) by misleading them about the benefits of irreversibly transferring their United Kingdom (“UK”) pensions to an offshore pension plan while concealing serious conflicts of interest, including the lucrative commissions Alderson Hamilton each stood to – and did – receive… Read More

Penalties: TBD
Respondent: Alderson, et al.
Violation: Former deVere USA CEO, Benjamin Alderson, and a former manager, Bradley Hamilton, misled clients and prospective clients about the benefits of pension transfers while concealing material conflicts of interest, including the substantial compensation that Alderson and Hamilton personally stood to receive… Read More

Penalties: $59,650.82
Respondent: Gary W. Freeman
Violation: This proceeding arises from Freeman’s “cherry-picking” of profitable trades to benefit himself. From at least July 17, 2012, through mid-September 2013 (the “relevant period”), Freeman disproportionately allocated profitable trades to himself, his wife, or his mother and disproportionately allocated unprofitable trades to his clients… Read More

Penalties: $75,000.00
Respondent: Veteri Place Corporation
Violation: This matter involves Veteri Place Corporation’s violations of the reporting provisions of Rule 204(b)-1 under the Advisers Act. Rule 204(b)-1 requires certain investment advisers with at least $150 million in private fund assets under management to file and periodically update a report on Form PF to provide information about the private funds they manage. From 2014 through 2016, Veteri was subject to the reporting requirements of Rule 204(b)-1, but failed to file or update a report on Form PF… Read More

Penalties: TBD
Respondent: Paul Gilman
Violation: Gilman used his companies – Oil Migration Group LLC, WaveTech29 LLC and GilmanSound LLC – to fraudulently solicit retail investors, including a nurse, a minister, and a businessman… Read More

Penalties: TBD
Respondent: SEC Complaint – Paul Gilman
Violation: Gilman, through entities he controls, defrauded investors in securities offerings related to his purported development of soundwave technology… Read More

Penalties: N/A
Respondent: Christopher C. Burtraw
Violation: Between March 2015 and August 2015, Burtraw unlawfully, and knowingly, without authorization or by threat or deception, obtained, retained, or exercised control over, or knowing or believing it to have been stolen, received, loaned money by pawn or pledge on, or disposed of, a thing of value, namely, cash/U.S. currency, check, and personal property, belonging to another individual with the intent to deprive that individual of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such a manner as to permanently deprive that individual of its use or benefit… Read More

Penalties: $438,989.00
Respondent: Gustavo A. Guzman
Violation: Guzman misappropriated approximately a third of the investors’ money, using it to pay himself and his personal expenses, and to make Ponzi payments to some of the investors. Guzman also allegedly sent investors false account statements and tax documents with exaggerated returns to conceal that he lost the remainder of the investors’ funds through unsuccessful options trading… Read More

Penalties: TBD
Respondent: Fern Holdings Corp., et al.
Violation: All of the Respondents are delinquent in their periodic filings with the Commission, have repeatedly failed to meet their obligations to file timely periodic reports, and failed to heed delinquency letters sent to them by the Division of Corporation Finance requesting compliance with their periodic filing obligations or, through their failure to maintain a valid address on file with the Commission as required by Commission rules, did not receive such letters. As a result of the foregoing, Respondents failed to comply with Exchange Act Section 13(a) and Rules 13a-1 and 13a-13… Read More

Penalties: $75,000.00
Respondent: Veteri Place Corporation
Violation: This matter involves Veteri Place Corporation’s violations of the reporting provisions of Rule 204(b)-1 under the Advisers Act. Rule 204(b)-1 requires certain investment advisers with at least $150 million in private fund assets under management to file and periodically update a report on Form PF to provide information about the private funds they manage. From 2014 through 2016, Veteri was subject to the reporting requirements of Rule 204(b)-1, but failed to file or update a report on Form PF… Read More

Penalties: TBD
Respondent: Barbara A. Endres
Violation: From approximately September 2016 through September 2017, Endres placed a number of her clients, some of whom were elderly, into an unsuitable, highly speculative investment strategy based on the short-term trading of a single security in advance of earnings announcements without disclosing the heightened risks associated with such a strategy… Read More

Penalties: $8,000,000.00
Respondent: deVere USA, Inc.
Violation: These proceedings arise out of investment adviser DVU’s failure to make full and fair disclosure to clients and prospective clients of material conflicts of interest regarding compensation obtained from third-party product and service providers… Read More

Penalties: N/A
Respondent: China Education Alliance, Inc., DoMark International, Inc., and East Coast Diversified Corp.
Violation: Pursuant to Section 12(j) of the Securities Exchange Act of 1934, the registrations of each class of registered securities of China Education Alliance, Inc., DoMark International, Inc., and East Coast Diversified Corp. are hereby revoked. The revocation is effective as of June 5, 2018… Read More

Penalties: TBD
Respondent: Edward Withrow, et al.
Violation: Making false statements in connection with his sworn investigative testimony to the SEC in August 2013 relating to questions about who owned approximately 40 million unrestricted shares of Endeavor’s stock, and whether Withrow ever tried to determine who owned those shares… Read More

Penalties: N/A
Respondent: Altona Resources, Inc., Apex 10, Inc. and Clone Algo, Inc.
Violation: Pursuant to Section 12(j) of the Securities Exchange Act of 1934, the registrations of each class of registered securities of Altona Resources, Inc., APEX 10, Inc., and Clone Algo, Inc., are revoked. The revocation is effective as of June 5, 2018… Read More

Penalties: $500,000.00
Respondent: Lyxor Asset Management, Inc.
Violation: This matter concerns a failure to disclose conflicts of interest by Lyxor Asset Management, Inc. (“Lyxor”), an investment adviser, to certain of its clients arising from an agreement (the “Side Letter”) between Lyxor and two affiliated outside asset managers (the “Third Party Advisers”)… Read More

Penalties: N/A
Respondent: Larry Werbel
Violation: Conspiracy to commit securities fraud in violation of Title 18, United States Code, Section 371 and one count of investment adviser fraud in violation of Title 15, United States Code, Section 80b-6… Read More

Penalties: TBD
Respondent: Jason A. Halek
Violation: Between September 2009 and June 2010, Halek, while acting as an unregistered broker, fraudulently offered and sold unregistered securities in the form of working interests in oil and gas projects that were owned and operated by Halek’s company, Halek Energy, LLC (“Halek Energy”)… Read More

Penalties: TBD
Respondent: Richard W. Kessler
Violation: From approximately March 2015 through August 2016, Kessler, the sole owner of an investment adviser, was a registered investment adviser representative and engaged in a number of prohibited business practices by an investment adviser under New Mexico state law, including taking custody of client funds without proper notice to the NMSD, failing to send account statements to clients, failing to maintain minimum capital and bond 2 requirements, failing to amend his Form U4 that was materially inaccurate and incomplete, and failing to distribute to clients a written disclosure statement and investment advisory contract… Read More

Penalties: TBD
Respondent: Titanium Blockchain Infrastructure Services, Inc., EHI Internetwork, and Systems Management, Inc. aka EHI-INSM, Inc., and Michael Alan Stollery aka Michael Stollaire
Violation: Titanium’s website contained fabricated testimonials from corporate customers and that Stollaire publicly – and fraudulently – claimed to have relationships with numerous corporate clients… Read More

Penalties: $50,000.00
Respondent: Michael J. Mona, Jr.
Violation: Mona made material misrepresentations and/or misleading omissions on CannaVEST’s quarterly reports filed with the SEC for CannaVEST’s first three quarters of 2013… Read More

Penalties: TBD
Respondent: Jehu Hand, et al.
Violation: Hand facilitated a scheme to pump and dump Greenway’s stock by authoring false legal opinion letters that were designed to evade restrictions on stock sales by company insiders and clear the way for Greenway stock held by him and other scheme participants to be sold to unsuspecting investors in the market… Read More

Penalties: $6,400,000.00
Respondent: Ralph T. Iannelli et al.
Violation: Between 2014 and 2017, Essex Capital Corporation and its founder, Ralph T. Iannelli, made a series of false and misleading statements and illusory personal guarantees to registered investment advisers to induce them to invest millions of dollars of their clients’ money in Essex’s failing equipment leasing business… Read More

Penalties: N/A
Respondent: Nachman Aaron Troodler, Esq.
Violation: Conspiracy to commit securities fraud and wire fraud, in violation of 18 U.S.C. § 371; and securities fraud, in violation of 15 U.S.C. §§ 78j(b) and 78ff, 17 C.F.R. § 240.10b-5, and 18 U.S.C. § 2… Read More

Penalties: $35,000.00
Respondent: Town of Ramapo, et al.
Violation: Hid a deteriorating financial situation from investors, from participating in municipal bond offerings… Read More

Penalties: $30,000.00
Respondent: GrandFund Investment Group, LLC
Violation: Between approximately December 2012 and June 2014, GrandFund failed to establish and implement a supervisory system for marketing expenses and charitable contributions in violation of NASD Rules 3010(a) and 3010(b) and FINRA Rule 2010. Between approximately December 2012 and January 2015, GrandFund failed to conduct adequate supervisory control system testing as required by NASD Rule 3012, and for 2014, failed to certify its supervisory controls in a timely fashion in violation of NASD Rule 3012 (for conduct before December 1, 2014), FINRA Rule 3120 (for conduct on or after December 1, 2014), and FINRA Rules 3130 and 2010… Read More

Penalties: $5,000.00
Respondent: Franklin I. Ogele
Violation: Between August 2014 and June 2015 (the “Relevant Period”), Ogele failed to supervise the trading activity of PF, one of BlackBook’s registered representatives, in violation of NASD Rule 3010 and FINRA Rules 3110 and 2010… Read More

Penalties: N/A
Respondent: Christopher T. Wendel
Violation: Between April and August 2017 (the “Relevant Period”), while associated with SA Stone, Wendel violated FINRA Rules 3280 and 2010 by engaging in private securities transactions without providing notice to SA Stone. In 2018, Wendel also violated FINRA Rules 8210 and 2010 by providing a false written response and false on-the-record (“OTR”) testimony concerning one of the private securities transactions… Read More

Penalties: N/A
Respondent: William David Nelson
Violation: Nelson refused to appear and provide testimony in response to a FINRA staff request made pursuant to FINRA Rule 8210, in violation of FINRA Rules 8210 and 2010… Read More

Penalties: N/A
Respondent: Francis Keyla Acosta
Violation: Acosta admitted to causing another person to impersonate AC on five telephone calls with another broker-dealer. At that time, Acosta also admitted to signing AC’s name on the replacement form and accompanying documents. By reason of the foregoing, Acosta violated FINRA Rule 2010… Read More

Penalties: $5,000.00
Respondent: Frank Dominic Corto
Violation: In or about June 2016, while associated with Summit, Corto caused telephone numbers for 322 of his clients to be removed from Summit’s database. His actions caused the Firm to maintain incomplete information in violation of Section 17(a) of the Securities Exchange Act of 1934 and Rule 17a-3 promulgated thereunder and FINRA Rules 4511(a) and 2010… Read More

Penalties: N/A
Respondent: Donnell Noah Bowen
Violation: Bowen failed to provide documents, information, and on-the-record testimony in response to FINRA’s Rule 8210 requests… Read More

Penalties: N/A
Respondent: Ellen Vratoric
Violation: For twice failing to provide sworn testimony requested pursuant to FINRA Rule 8210… Read More

Penalties: N/A
Respondent: Bradley Everett Gardner
Violation: In June 2017, Gardner accepted a personal check in the amount of $7,400 from his elderly Firm customer, who believed she was pre-paying her advisory account fees. However, Gardner deposited the check into his personal bank account and used the funds to pay for his personal expenses. By converting customer funds, Gardner violated FINRA Rules 2150(a) and 2010… Read More

Penalties: N/A
Respondent: James Edward Lyons
Violation: Lyons acknowledges that he received FINRA’s request and will not appear for on-the-record testimony at any time. By virtue of the foregoing, Lyons violates FINRA Rules 8210 and 2010… Read More

Penalties: N/A
Respondent: John Douglas Wade
Violation: From February 2013 through July 2017, Wade converted more than $105,000 from two elderly USBI customers. As a result, Wade violated FINRA Rules 2150(a) and 2010… Read More

Penalties: $10,000.00
Respondent: Kevin Edward Looser
Violation: From September 2011 through July 2014 (the “Relevant Period”), Looser violated NASD Rule 3040 and FINRA Rule 2010 by participating in fourteen private securities transactions without providing prior written notice to his employer firm… Read More

Penalties: $37,500.00
Respondent: Buckman, Buckman & Reid, Inc.
Violation: BKRT’s supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to FINRA Rule 7450, as the firm was unaware of its OATS reporting obligations involving the ROEs it failed to report during the Review Period… Read More

Penalties: N/A
Respondent: Atiq U. Khan
Violation: On September 8, 2017, and October 11, 2017, Atiq U. Khan failed to appear for testimony in response to two requests sent to him by FINRA Staff pursuant to FINRA Rule 8210… Read More

Penalties: N/A
Respondent: Sean Aaron Brady
Violation: During the course of an ongoing examination, Brady did not respond to requests for information and documents made by FINRA pursuant to FINRA Rule 8210. As a result, Brady violated FINRA Rules 8210 and 2010… Read More

Penalties: $10,000.00
Respondent: Alexander L. Martin
Violation: During the period from November 2012 through March 2015, Martin, while serving as co-President of CSSC Brokerage Services, Inc. (“CSSC B/D”), failed to reasonably supervise registered representatives selling two private offerings, including registered representative DS. DS lacked a reasonable basis for recommending the offerings to his customers and caused two specific customers to over-concentrate their accounts in illiquid private offerings that were inconsistent with their investment objectives and risk tolerance… Read More

Penalties: N/A
Respondent: Michael P. Spolar
Violation: Between July 30, 2016 and July 14, 2017, Spolar, while associated with FINRA member IAA, issued nine personal checks, totaling approximately $2,100, to customer FJ in an effort to reimburse the customer for losses he sustained in investments he made in options, in violation of FINRA Rules 2150(c) and 2010… Read More

Penalties: $5,000.00
Respondent: Bridgett Lashawn Perry (“Perry” or “Respondent”)
Violation: Perry violated FINRA Rule 2010, and FINRA Rules 4511 and 2010 by causing her FINRA-regulated broker-dealer employer to create and maintain inaccurate books and records in violation of Section 17(a) of the Securities Exchange Act of 1934 (“Exchange Act”) and Rule 17a-3 thereunder… Read More

Penalties: $5,000.00
Respondent: Paula Darline Galbadores
Violation: While associated with the Firm, Galbadores failed to timely amend her Form U4 to disclose that she had been charged with various felony crimes involving the theft of personal identifying information and money. She learned of the charges on May 22, 2016, and did not disclose them to the Firm until October 26, 2016 — four months after she was required to do so. Galbadores also failed to amend her Form U4 to disclose her subsequent nolo contendere guilty plea to two felony charges on November 16, 2016. By virtue of this conduct, Galbadores willfully violated Article V, Section 2(c) of FINRA’s By-Laws, and FINRA Rules 1122 and 2010… Read More

Penalties: $20,000.00
Respondent: Alexander Souponetsky
Violation: Between February 2015 and March 2016, Souponetsky exercised discretion without written authorization in the accounts of four customers and mismarked as “unsolicited” orders for an inverse exchange-traded product (“ETP”) in the accounts of seven customers. Souponetsky also failed to disclose an outside business activity and submitted a false compliance questionnaire. By virtue of the foregoing, Souponetsky violated NASD Rule 2510(b) and FINRA Rules 4511, 3270 and 2010… Read More

Penalties: N/A
Respondent: James P. Acosta
Violation: In April 2018, Respondent violated FINRA Rules 8210 and 2010 by failing to appear for on-the-record testimony requested pursuant to FINRA Rule 8210… Read More

Penalties: N/A
Respondent: Ruben Gerardo Aleman Escalante
Violation: On July 3, 2017, while registered as an Investment Company Products/Variable Contracts Representative with the Finn, a FINRA-regulated broker-dealer, and dually employed as a personal banker with the Affiliate Bank, Aleman converted $800 from an Affiliate Bank customer by using the customer’s bank debit card to withdraw the funds without the customer’s knowledge or approval, in violation of F1NRA Rule 2010… Read More