FINRA

Dickinson was named a respondent in a FINRA complaint alleging that he failed to conduct adequate and reasonable due diligence on a private placement securities offering and, therefore, did not have a reasonable basis to recommend it to any customers who purchased it upon his recommendation. The complaint alleges that Dickinson sold to customers limited partnership interests in the private placement securities offering that offered investors the opportunity to acquire an income stream derived from the acquisition and operation of automated teller machines (ATMs). Had Dickinson conducted adequate and reasonable due diligence on the private placement securities offering, he would have detected multiple red flags indicating that the underlying purchase and operation of the ATMs was fraudulent. Dickinson's customers suffered a total loss of over a million dollars because the underlying business scheme of the offering was a fraud and most of the ATMs were fictional.

Decision

Bar (Permanent)

All Capacities

11/18/2016

Restitution

$924,000.00

Default decision rendered October 21, 2016. The sanctions were based on findings that Dickinson sold securities without reasonable grounds for believing that the investment was suitable for any investor. The findings stated that Dickinson failed to conduct adequate and reasonable due diligence on a private placement securities offering of limited partnership interests in ATM Alliance, LP (ATMA) to customers and did not have a reasonable basis to recommend it to any of the customers who purchased it upon his recommendation. Dickinson sold more than $1 million of the limited partnership interests in ATMA to customers and he recommended the securities without first conducting adequate and reasonable due diligence on ATMA. ATMA's purported business was to acquire and operate automated teller machines (ATMs). In fact, it did not own any ATMs. Dickinson failed to verify or confirm information he obtained from interested parties and failed to detect multiple red flag warnings that ATMA was a fraudulent Ponzi scheme. As a result, the customers lost their entire investments. If Dickinson had conducted a reasonable investigation, he would have recognized red flags indicating that the offering was fraudulent and thus unsuitable for any investors regardless of their wealth, risk tolerance, age, or other individual characteristics. The findings also stated that Dickinson told investors that ATMA was to purchase ATMs and contract with an entity called ATM Financial Services (ATMFS) to manage and service the ATMs at various locations, such as convenience stores and supermarkets. ATMFS would hold a lease with the owner of the property where an ATM was located. Revenue generated from the use of the ATMs would go to investors, as well as to pay for servicing and the lease costs. For Dickinson's due diligence, he took several steps, but they were inadequate and incomplete. The decision became final November 18, 2016.

TEXAS

Decision

Revocation/Expulsion/Denial