FINRA

Ingram was named a respondent in a FINRA complaint alleging that he lacked a reasonable-basis to recommend unit investment trusts (UITs) and alternative investments. The complaint alleges that Ingram recommended that his customers purchase standard version units that caused the customers to incur transactional sales charges, instead of the fee-based units of the same UIT that would have avoided most of these same transactional sales charges and which were available to the customers. Ingram was aware of the costs and expenses and his ability to purchase the fee-based UITs. Despite understanding that his customers would have benefited from purchasing the fee-based UITs by paying lower costs for the same security, Ingram nonetheless recommended and purchased the standard version UITs in his customers' accounts for his own financial benefit and to the detriment of his customers. Ingram also recommended that nine of his customers purchase alternative investments through his member firm thereby incurring selling commissions that could have been avoided had he instead recommended that his customers purchase the same alternative investments for less that were available as a result of the customers' investment advisory agreement through Ingram's investment advisory firm. Ingram was aware of the costs and expenses and his ability to enter into selling agreements with alternative investment issuers on behalf of Ingram's investment advisory firm that would have allowed his customers to avoid paying selling commissions. Despite understanding that his customers would have benefited from purchasing the lower-cost alternative investments through his own investment advisory firm, Ingram nonetheless recommended and purchased alternative investments through his member firm for his own financial benefit and to the detriment of his customers. Ingram had no reasonable basis to recommend that his customers purchase the more expensive standard version UITs and to purchase alternative investments through the firm when he knew that these same customers could have purchased these investments for less and received the same benefits. The complaint also alleges that Ingram did not act with commercial honor and observe just and equitable principles of trade.

Decision & Order of Offer of Settlement

Civil and Administrative Penalty(ies)/Fine(s)

$15,000.00

Restitution

$388,962.13

Suspension

All Capacities

Six Months

5/15/2023

11/14/2023

Without admitting or denying the allegations, Ingram consented to the sanctions and to the entry of findings that he lacked a reasonable basis to recommend UITs and alternative investments. The findings stated that Ingram recommended that his customers purchase standard version units that caused the customers to incur transactional sales charges, instead of the fee-based units of the same UIT that would have avoided most of these same transactional sales charges and which were available to the customers. Ingram was aware of the costs and expenses and his ability to purchase the fee-based UITs. Despite understanding that his customers would have benefited from purchasing the fee-based UITs by paying lower costs for the same security, Ingram nonetheless recommended and purchased the standard version UITs in his customers' accounts for his own financial benefit and to the detriment of his customers. Ingram also recommended that nine of his customers purchase alternative investments through his member firm thereby incurring selling commissions that could have been avoided had he instead recommended that his customers purchase the same investments for less that were available as a result of the customers' investment advisory agreement through his investment advisory firm. Ingram was aware of the costs and expenses and his ability to enter into selling agreements with these issuers on behalf of his investment advisory firm that would have allowed his customers to avoid paying selling commissions. Despite understanding that his customers would have benefited from purchasing the lower-cost investments through his investment advisory firm, Ingram nonetheless recommended and purchased alternative investments through the firm for his own financial benefit and to the detriment of his customers. Ingram had no reasonable basis to recommend that his customers purchase the more expensive standard version UITs and to purchase alternative investments through the firm when he knew that these same customers could have purchased these investments for less and received the same benefits. The findings also stated that Ingram did not act with commercial honor and observe just and equitable principles of trade when he recommended that his customers purchase the more expensive standard version UITs when the fee-based UITs were equally available at a lower cost. Similarly, Ingram did not act with commercial honor and observe just and equitable principles of trade when he recommended that his customers purchase alternative investments through the firm when he knew that these same customers could have purchased these investments without paying selling commissions based on the customers' investment advisory relationship with his investment advisory firm.

CLAIMANT ALLEGES THE SUBJECT SOLD HER UNSUITABLE INVESTMENTS IN BONDS AND REITS. THE SUBJECT IS NOT NAMED IN THE ARBITRATION.

$270,000.00

$23,000.00

THE SUBJECT IS NOT NAMED IN THE ARBITRATION.

ALLEGED UNSUITABILITY OF INVESTMENTS MADE FROM 2003-2015.

$906,353.70

$200,000.00

ALLEGED UNSUITABILITY OF INVESTMENTS MADE FROM 2005-2011.

$222,266.50

$46,000.00

THE REGISTERED REPRESENTATIVE VEHEMENTLY DENIES ANY WRONGDOING AND INTENDS TO VIGOROUSLY DEFEND THIS MATTER TO THE FULLEST EXTENT.

CLIENT CLAIMS RESPONDENT SOLD HIM UNSUITABLE INVESTMENTS.

$230,456.56

$45,000.00

THE REGISTERED REPRESENTATIVE VEHEMENTLY DENIES ANY WRONGDOING AND INTENDS TO VIGOROUSLY DEFEND THIS MATTER TO THE FULLEST EXTENT.

Client alleges over concentrated and unsuitable investments. No losses are alleged.

$308,437.98

$115,000.00

It should be noted that nowhere is it alleged that the client lost any money or that she did not receive the income she needed. I spent significant time conducting due diligence on the client, her needs and the ultimate investments. All investments were both suitable and thoroughly explained to the client. This is evidenced by over fifteen signatures on documents where the client attested she understood and accepted the risks of the investments. At all times, I put the client's interest first and I will vigorously defend this matter to the fullest extent of the law.

Suitability of investments made between 2008 & 2011.

$100,000.00

$112,500.00

RR intends to vigorously defend against the Claimants' allegations.

SUITABILITY, ALLEGED INVESTMENT LOSSES

$309,275.00

CLAIMANTS' ALLEGATIONS WERE PREVIOUSLY MADE BY WAY OF A NON-REPORTABLE VERBAL COMPLAINT. CLAIMANTS HAD ELECTED TO RELEASE ALL CLAIMS FOR ALL INVESTMENTS IN RETURN FOR A SETTLEMENT OF $14,900. THIS SUBSEQUENT WRITTEN CLAIM IS DUPLICATIVE AND HAS THEREFORE BEEN DENIED AS PREVIOUSLY RESOLVED.

CUSTOMER IS A CLAIMANT IN A MULTI-CLAIMANT ACTION INVOLVING CUSTOMERS OF ANOTHER AGENT. ALLEGATIONS ARE UNSUITABILITY AND LACK OF DUE DILIGENCE FOR AN INVESTMENT IN INLAND WESTERN REIT IN 2004. SEE COMMENTS BELOW FOR ADDITIONAL INFORMATION.

$683,000.00

$1,167.60

THE RESOLUTION OF THIS MATTER BY SETTLEMENT IS NEITHER AN ADMISSION NOR EVIDENCE OF WRONGOING. BUSINESS DECISION MADE TO DISPENSE WITH THIS MATTER IN ADVANCE OF HEARING TO AVOID THE TIME AND EXPENSE ASSOCIATED WITH PROTRACTED LITIGATION

SUITABILITY.

$500,000.00

$232,500.00

FIRM MAINTAINS SUITABILITY OF INVESTMENTS. BUSINESS DECISION MADE TO RESOLVE THE MATTER TO AVOID THE TIME AND EXPENSE ASSOCIATED WITH PROTRACTED LITIGATION.