UNITED STATES SECURITIES AND EXCHANGE COMMISSION

The Securities and Exchange Commission ("Commission") deems it appropriate and in the public interest that public administrative proceedings be, and hereby are, instituted against Tarek D. Bahgat ("Bahgat" or "Respondent"). After an investigation, the Division of Enforcement alleges that: on September 28, 2017, the Commission filed a civil injunctive action against Bahgat in the United States District Court for the Southern District of New York Case No. 1:17-cv-00971-LJV (W.D.N.Y.). The Commission's complaint alleged that, from at least December 2014 through September 2016, Bahgat, misappropriated approximately $378,000 from his investment advisory clients by, among other things, accessing his clients' brokerage accounts and causing transfers from the client accounts to accounts Bahgat controlled. On May 17, 2023, the Court entered a decision and order granting the Commission's motion for a default judgment against Bahgat finding, among other things, that the Commission's efforts to serve Bahgat with the Complaint in Egypt satisfied the constitutional requirements of the Fourteenth Amendment's due process clause. On June 6, 2023, the Court entered a Final Judgment as to Defendant Tarek D. Bahgat, which enjoined Bahgat from violating Sections 206(1) and 206(2) of the Advisers Act, and also ordered Bahgat to disgorge $378,021.97, representing net profits gained as a result of the conduct alleged in the Complaint, plus $142,057.43 in prejudgment interest, and a civil penalty of $378,854.

FINRA

Respondent Bahgat failed to comply with an arbitration award or settlement agreement or to satisfactorily respond to a FINRA request to provide information concerning the status of compliance.

letter

Suspension

All capacities

Indefinite

Continues until required payment is made or discharged.

3/27/2018

Pursuant to Article VI, Section 3 of FINRA By-Laws, and FINRA Rule 9554, Respondent Bahgat is suspended on March 27, 2018, for failure to comply with an arbitration award or settlement agreement or to satisfactorily respond to a FINRA request to provide information concerning the status of compliance.

UNITED STATES SECURITIES AND EXCHANGE COMMISSION

SEC Litigation Release No. 23951/September 29, 2017: The SEC's complaint alleges that Tarek D. Bahgat, a former resident of Williamsville, N.Y. who now lives in Egypt, misappropriated money from seven of his investment advisory clients, many of whom were senior citizens. The SEC also alleges that, in some instances, Bahgat, by obtaining internet bill-paying privileges, impersonated his clients in telephone calls with broker-dealers holding the client accounts and caused money to be transferred from his clients' accounts to himself or to a company Bahgat controlled. The SEC's complaint charges Bahgat with violating Sections 206(1) and 206(2) of the Investment Advisers Act of 1940.

Judgment Rendered

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

Disgorgement

$378,021.97

Monetary Penalty other than Fines

Injunction

FINRA

Respondent Bahgat failed to respond to FINRA request for information.

Letter

Bar (Permanent)

All Capacities

Indefinite

3/23/2017

Pursuant to FINRA Rule 9552(h) and in accordance with FINRA's Notice of Suspension and Suspension from Association letters dated December 20, 2016 and January 13, 2017, respectively, on March 23, 2017, Bahgat is barred from association with any FINRA member in any capacity. Respondent failed to request termination of his suspension within three months of the date of the Notice of Suspension; therefore, he is automatically barred from association with any FINRA member in any capacity.

Client alleges that misrepresentations were made in connection with his purchase of a non-qualified variable annuity in August of 2016.

NEW YORK CLIENT COMPLAINS THAT THE VARIABLE UNIVERSAL LIFE POLICY DELIVERED ON DECEMBER 2, 2003, PURCHASED AT THE RECOMMENDATION OF FINANCIAL ADVISOR TERRY BAHGAT, DOES NOT MATCH THE TERMS IN THE ORIGINAL PROPOSAL. SPECIFICALLY, CLIENT CLAIMS THE FACE AMOUNT OF THE COVERAGE SHOULD HAVE BEEN $600,000 FOR AN ANNUAL PREMIUM OF $11,000 BUT WAS INSTEAD $328,000 IN COVERAGE FOR A PREMIUM OF $20,000. CLIENT REQUESTS THE ORIGINAL PROPOSAL BE HONORED AS REMEDY.

$5,001.00

CLIENTS CLAIM RESOLVED BY MANULIFE FINANCIAL. ON AUGUST 15, 2003, THE CLIENT WAS EXTENDED A VARIABLE UNIVERSAL LIFE POLICY WITH A DEATH BENEFIT OF $600,000 AND ANNUAL PREMIUMS AS REQUESTED THROUGH ANOTHER AGENT APPOINTED BY MANULIFE. ON REVIEW, THERE IS NO EVIDENCE THAT WACHOVIA SECURITIES FINANCIAL NETWORK ADVISOR, TERRY BAHGAT, MISREPRESENTED THE TERMS OF THE INITIAL POLICY OFFERED. RATHER THE COMPLAINT APPEARS TO HAVE ORIGINATED IN A GENERAL MISCOMMUNICATION BETWEEN MANULIFE, THE CLIENT AND MR. BAHGAT, WHICH MANULIFE'S OFFER HAS RESOLVED.

CUSTOMERS COMPLIANED OF SUITABILITY AND LOSSES FROM MUTUAL FUND PURCHASES

$10,000.00

$9,215.24