State of California Department of Insurance

Failure to report the FINRA Suspension and Fine from 2016 within 30 days.

Order

Suspension

Suspension of Insurance Licenses

two weeks

10/16/2017

10/29/2017

Bankruptcy

Discharged

FINRA

Without admitting or denying the findings, Graham consented to the sanctions and to the entry of findings that while associated with his member firm, Graham borrowed $15,000 from an elderly customer and that during this time, the firm's policy and procedures permitted borrowing from customers under certain circumstances, and with prior approval from the firm. The findings stated that Graham did not disclose his borrowing to the firm. This conduct was aggravated by the fact that Graham completed the firm's annual questionnaire attesting affirmatively that he was aware that he was not "permitted to borrow money from or lend money to any client." The findings also stated that Graham has repaid the loan in full.

Acceptance, Waiver & Consent(AWC)

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

$5,000.00

Suspension

Any Capacity

45 days

4/18/2016

6/1/2016

The money that I borrowed was from a close family friend and client for over twenty years. I paid off the loan. I did not think it was inappropriate at the time. Gary Graham

ALLEGED UNAUTHORIZED TRADES

$10,000.00

A CATEGORICALLY DENY THIS ALLEGATION. THIS SETTLEMENT WAS MADE WITHOUT MY KNOWLEDGE. I WAS NOT AWARE OF ANY COMPLAINT THAT EXISTED; NOR WAS I EVER CONTACTED UNTIL AFTER THE COMPLAINT WAS SETTLED. I ALSO DID NOT PARTICIPATE IN ANY SETTLEMENT.