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 pursuant to Section 203(f) of the Investment Advisers Act of 1940 ("Advisers Act") against Ramiro Jose Sugranes ("Respondent"). The Commission finds that on October 3, 2022, a final judgment was entered by consent against Respondent Ramiro Jose Sugranes, permanently enjoining him from future violations of Sections 17(a)(1) and (3) of the Securities Act of 1933 , Section 10(b) of the Securities Exchange Act of 1934 and Rules 10b-5(a) and (c) thereunder, and Sections 206(1) and 206(2) of the Advisers Act, in the civil action entitled Securities and Exchange Commission v. Ramiro Jose Sugranes, et al., Civil Action Number 21-cv-22152, in the United States District Court for the Southern District of Florida. The Commission's complaint alleged that Sugranes and others engaged in a long-running cherry-picking scheme. Over a more than four year period, thousands of profitable trades worth more than $4 million were allocated to two preferred accounts after the security went up in value. In addition, millions of dollars of unprofitable trades in securities were allocated to other investment advisory client accounts if the security went down in value.

Order

Bar (Permanent)

association with a broker, dealer, investment adviser, municipal securities dealer, municipal advisor, transfer agent, or NRSRO

Indefinite

10/24/2022

To avoid the cost of additional litigation, without admitting or denying the allegations, Mr. Sugranes elected to enter into a settlement agreement with the SEC.

UNITED STATES SECURITIES AND EXCHANGE COMMISSION

The Securities and Exchange Commission (the "Commission"), for its Complaint against Defendants Ramiro Jose Sugranes ("Sugranes"), UCB Financial Advisers, Inc. ("UCB Advisers"), and UCB Financial Services, Limited ("UCB Services") ( collectively, the "Defendants") and Relief Defendants Ramiro Sugranes Hernandez and Thelma Lanzas De Sugranes (collectively, the "Relief Defendants"), alleges that Defendant Sugranes, through UCB Advisers and UCB Services (collectively, the "UCB Entities"), engaged in a long-running fraudulent trade allocation scheme - commonly referred to as "cherry picking." Defendants' allocated thousands of profitable trades worth more than $4 million in stocks and options on securities ("Options") to two preferred accounts held at the UCB Entities in the name of the Relief Defendants Ramiro Sugranes Hernandez and Thelma Lanzas De Sugranes, who are Sugranes' parents or relatives ( collectively, "Preferred Accounts"). Sugranes also allocated millions of dollars of unprofitable trades to other investment advisory client accounts with the UCB Entities. This scheme is ongoing. The SEC brings this enforcement action to stop this fraud and return the ill-gotten gains to the harmed investors. Sugranes perpetrated this fraud through UCB Services and UCB Advisers, an investment advisory firm of which he is a partial owner. He carries out the cherry-picking scheme by first using an average price trading account used by the UCB Entities to purchase stocks and Options on behalf of numerous client accounts. Sugranes then allocates those trades to specific accounts, typically later that same day. If the position increases in value during that day, the position is usually closed out, thereby locking in the same-day profit, and the opening and closing trades and the corresponding profits are allocated to one of the Preferred Accounts. If the value of the trades decrease during that day, the position (which is worth less at the time of allocation than it was at the time of purchase and thereby has a first day loss) is usually allocated to [the account(s) of] one or more of the UCB Entities' other clients (the "Non-Preferred Accounts"). This cherry-picking scheme funneled approximately $4.6 million in illicit profits to the Preferred Accounts, and negatively impacted at least 75 Non-Preferred Accounts that suffered first day losses. In total, the Non-Preferred Accounts were allocated more than $5.5 million of first day losses with 16 of the Non-Preferred Accounts sustaining more than $25,000 in first day losses, and two other Non-Preferred Accounts sustaining more than $1 million in first day losses. From this fraud, the Defendants received ill-gotten gains and benefits and the Relief Defendants received illicit proceeds from the Defendants' fraud to which they have no legitimate claim. By engaging in the fraudulent conduct described herein, Defendants violated and, unless they are restrained and enjoined, will continue to violate Section 17(a)(1) and (3) of the Securities Act of 1933 ("Securities Act"), Section 10(b) of the Securities Exchange Act of 1934 ("Exchange Act"), Exchange Act Rule 10b-5(a) and (c), and Sections 206(1) and 206(2) of the Investment Advisers Act of 1940 ("Advisers Act").

Judgment Rendered

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

Disgorgement

$2,118,610.00

$2,481,390.00

Monetary Penalty other than Fines

Injunction

To avoid the cost of additional litigation, without admitting or denying the allegations, Mr. Sugranes elected to enter into a settlement agreement with the SEC.

NASD

VIOLATION OF NASD CONDUCT RULES 2110 AND 2510(B); RESPONDENT SUGRANES EXERCISED DISCRETION IN THE SECURITIES ACOUNTS OF A PUBLIC CUSTOMER, WITHOUT HAVING SAID DISCRETION REDUCED TO WRITING AND WITHOUT HAVING THE ACCOUNTS APPROVED AS DISCRETIONARY BY HIS MEMBER FIRM.

Acceptance, Waiver & Consent(AWC)

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

Suspension

WITHOUT ADMITTING OR DENYING ALLEGATIONS, RESPONDENT CONSENTED TO DESCRIBED SANCTIONS AND ENTRY OF FINDINGS; THEREFORE, HE IS FINED $7,500 AND SUSPENDED FROM ASSOCIATION WITH ANY NASD MEMBER IN ALL CAPACITIES FOR 30 DAYS. THE SUSPENSION SHALL COMMENCE ON APRIL 4, 2005, AND WILL CONCLUDE ON MAY 3, 2005. FINES PAID.

APPLICANT OBTAINED WRITTEN DISCRETIONARY AUTHORITY FROM CLIENT WHILE APPLICANT WAS EMPLOYED BY PREVIOUS BROKER DEALER FIRM. CLIENT SIGNED AFFIDAVIT CONFIRMING THAT DISCRETIONARY AUTHORITY WAS GIVEN TO APPLICANT. NO CUSTOMER COMPLAINT WAS FILED WITH RESPECT TO THIS MATTER.

GLOBAL INVESTOR SERVICES

Permitted to Resign

THE FIRM NOTED CERTAIN IRREGULARITIES RELATING TO CHECKS DRAWN ON A CLIENT'S ACCOUNTS AS WELL AS ON THE SUPPORTING DOCUMENTATION THEREFOR. THE FIRM INITIATED AN INTERNAL REVIEW AND LEARNED FROM THE CLIENT (WHO PROVIDED AN AFFIDAVIT DATED AFTER THE CHECKS) INDICATING, AMONG OTHER THINGS, THAT THE CLIENT IS RELATED TO THE INDIVIDUAL AND THAT THE TRANSACTIONS HAD BEEN AUTHORIZED BY THE CLIENT. HOWEVER, THE FIRM CONCLUDED FROM ITS INTERNAL REVIEW THAT THE INDIVIDUAL FAILED TO FOLLOW THE FIRM'S PROCEDURES REGARDING DOCUMENTATION OF THE TRANSACTIONS.

CLIENT SIGNED AFFIDAVIT CONFIRMING THAT DISCRETIONARY AUTHORITY WAS GIVEN TO APPLICANT. NO CUSTOMER COMPLAINT WAS FILED WITH RESPECT TO THIS MATTER.

NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Decision

Monetary/Fine

$10,000.00

Disgorgement/Restitution

Censure

Suspension

BAC CORP SECURITIES, ALLEGEDLY REPORTED A VERBAL COMPLAINT BY THE CLIENT "CARIBBEAN BASIN INVESTMENTS", REGARDING MATERIAL MISREPRESENTATIONS MADE TO THE CLIENT.

$44,979.21

ALLEGEDLY BAC CORP. SECURITIES SETTLED WITH THE CLIENT "CARIBBEAN BASIN INVESTMENTS" FOR THE AMOUNT OF $44,979.21. PLEASE SEE INFORMATION THAT HAS ALREADY BEEN FORWARDED TO THE NASD, REGARDING THE ENTIRE DESCRIPTION OF THE ABOVE MENTIONED COMPLAINT NUMBER.

BAC CORP. SECURITIES

Discharged

NOT PROVIDED ALLEGED VERBAL CUSTOMER COMPLAINT THAT I FALSIFIED A LETTER OF GUARANTEE. THE CLIENT DID NOT LOSE A PENNY ON HIS INVESTMENTS.

DISCHARGED SEE ATTACHED.