FINRA

Without admitting or denying the findings, Lamkin consented to the sanctions and to the entry of findings that he borrowed a total of $1,265,000 from a customer whose account he serviced without notifying his member firm or obtaining its written approval. The findings stated that Lamkin's customer was a longtime friend who was also a customer of the firm. The first loan in the amount of $740,000, was made via a promissory note signed by Lamkin's wife and secured by a mortgage identifying Lamkin and his wife as the borrowers and signed by both. That loan has been repaid in full. The second loan, in the amount of $250,000, was negotiated between Lamkin and the customer and memorialized by a note signed by Lamkin's wife. The third loan, in the amount of $275,000, was made to an LLC of which Lamkin was a member and initially was memorialized by a note signed by Lamkin and his business partner. While the second and third loans have not been repaid in full, they are currently in repayment. The customer was not Lamkin's family member and the firm's WSPs prohibited registered representatives from borrowing money from a customer unless the customer was a family member. The findings also stated that in annual compliance questionnaires Lamkin falsely affirmed that neither he nor any related person or entity had borrowed or loaned any money or securities from or to another individual or entity.

Acceptance, Waiver & Consent(AWC)

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

$7,500.00

Suspension

All capacities

Three months

4/20/2020

7/19/2020

"Finra did a great job in their investigation and i fully admit to arranging a loan from a long time friend that i mistakenly believed was exempt from FINRA guidelines. They are 100% correct in their findings and to this day, the friend is a client and fully supports our arrangement and agreement."

Kentucky

Respondent transacted business in the state as an IA and IAR while unregistered due to his failure to remove himself from an account- receiving money earned by others registered with by LPL financial.

Settled

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

$1,000.00

Heightened supervision for a period of one year. Three month suspension entered but waived if Respondent commits no violations of the Act for a period of three years.

The Final Order represents a negotiated settlement with the State of KY. Initially, following an evidentiary hearing, the ALJ dismissed KY's case in its entirety. In its review of that Order, however, the State Securities Commissioner reversed the ALJ, which finding Mr. Lamkin then appealed to court. Before a final hearing in that matter, the parties agreed to settle. The Agreed Order explicitly recites that although Mr. Lamkin "did not exercise actual, practical control over LWM or its bank accounts during the time he was unregistered, nor attempt to pay himself any money from such accounts," because he still "legally controlled" the bank accounts, he is deemed to have transacted business as an investment adviser.

LPL Financial LLC

Discharged

Allegations that advisor received and/or benefitted from loans from Firm customers, failed to disclose and inadequately disclosed outside business activities, and personally engaged in and solicited other investors to participate in private investments without obtaining Firm approval.

I deny all of the allegations made by LPL, and will contest them vigorously. These allegations have been conjured up by LPL as a subterfuge, to justify its efforts to damage my reputation and, as a result, take my customers.

PNC BROKERAGE

Voluntary Resignation

PNC BROKERAGE CORP. WAS INVESTIGATING THE NATURE AND PURPOSE OF FUNDS TRANSFERRED BETWEEN MR. LAMKIN AND A WORK ASSOCIATE. ALTHOUGH THIS INVESTIGATION WAS INCONCLUSIVE PNC BROKERAGE CORP. DETERMINED THAT MR. LAMKIN FAILED TO REPORT TO MANAGEMENT THAT A WORK ASSOCIATE ACCESSED LAMKIN'S BANK ACCOUNT WITHOUT LAMKIN'S KNOWLEDGE.

UPON DISCOVERING THE ACTIVITY OF MY ASSOCIATE, I CORRECTED HIS BEHAVIOR AND ASCERTAINED THAT IT WOULD NEVER HAPPEN AGAIN AND IT DID NOT. NINE MONTHS LATER, DURING AN INVESTIGATION OF THIS ASSOCIATE, I DISCLOSED THE ABOVE MENTIONED ACTIVIITY TO PNC BROKERAGE.