FINRA

Without admitting or denying the findings, Silvestri consented to the sanction and to the entry of findings that he refused to appear for on-the-record testimony requested by FINRA in connection to its investigation into whether he borrowed funds from a customer.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All capacities

Indefinite

11/21/2023

AEGIS CAPITAL CORP.

Discharged

The Firm received an alert that Mr. Silvestri's license had been amended by his prior broker-dealer to reflect that he had borrowed money from a client that he serviced at both his prior broker-dealer and who was a current client. At or around the same time, the Firm received a phone call from the customer who advised the Firm that she had loaned Mr. Silvestri money while he was registered with his prior firm as well as when he was registered with the Firm. The Firm immediately investigated the matter and determined that Mr. Silvestri did in fact borrow funds from a client without the Firm's knowledge, consent or approval. The Firm terminated Mr. Silvestri and has reimbursed the client for the amount of the loan.

Level Four Advisory Services, LLC

Discharged

Mr. Silvestri failed to follow the firm's stated policies and procedures relating to disclosure information.

The customer alleges unsuitable recommendations in her fee-based account since account inception (February 2020) to present which resulted in losses in her account. Customer additionally alleges that representative wrote personal checks to cover some of the losses in her account.

$9,500.00

$8,000.00

UNSUITABILITY, MISREPRESENTATIONS AND OMISSIONS, AND BREACH OF FIDUCIARY DUTY.

THE PARTIES SIGNED A STIPULATED AWARD REQUESTING THAT THE ARBITRATION PANEL RECOMMEND THE EXPUNGEMENT OF ALL REFERENCES TO THE ABOVE-CAPTIONED ARBITRATION FROM RESPONDENT ROBERT SILVESTRI'S REGISTRATION RECORDS MAINTAINED AT THE NASD'S CRD.