ROGER THOMAS DENHA - Investment Adviser

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Detailed ReportReport

ROGER THOMAS DENHA

CRD#: 2468173

Previous Investment Adviser

Previous Broker

BARRED BY FINRA OR THE SEC

The SEC has barred this individual from acting as a broker or investment adviser or otherwise associating with firms that sell securities or provide investment advice to the public.

The representative was previously registered both as an investment adviser and as a broker. Visit BrokerCheck for more information on this individual's Broker record. Go to BrokerCheck Site

Licenses

Licenses

0 Licenses

Registration History

Disclosure(s)

View By:

8/17/2018

Regulatory

Final

Initiated By

UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Allegations

SEC Admin Release 34-83873, IA Release 40-4988, Investment Company Act of 1940 Release 33202 / August 17, 2018: The United States Securities and Exchange Commission (the "Commission") deems it appropriate and in the public interest that public administrative and cease-and-desist proceedings be, and hereby are, instituted pursuant to Sections 15(b) and 21C of the Securities Exchange Act of 1934 ("Exchange Act"), Sections 203(f) and 203(k) of the Investment Advisers Act of 1940 ("Advisers Act"), and Section 9(b) of the Investment Company Act of 1940 ("Investment Company Act") against Roger T. Denha ("Denha"). The Commission finds that from at least January 2012 to November 2017 (the "relevant time period"), Roger T. Denha, an investment adviser and investment adviser representative of BKS Advisors LLC ("BKS"), an investment adviser registered with Commission and based in Southfield, Michigan, engaged in fraudulent trade allocation, or "cherry-picking." Denha executed his cherry-picking scheme by unfairly allocating purchases of securities between his favored accounts (including his personal and family accounts) and his other BKS clients' accounts. Denha disproportionately allocated profitable trades to the favored accounts, and disproportionately allocated unprofitable trades to the accounts of certain advisory clients. He executed his scheme by buying the securities in an omnibus account and then waiting to allocate until after he had an opportunity to see whether the securities had increased in price. By virtue of his conduct, Denha willfully violated Section 10(b) of the Exchange Act and Rules 10b-5(a) and 10b-5(c) thereunder and Sections 206(1) and 206(2) of the Advisers Act.

Resolution

Order

Bar

Bar (Permanent)

Registration Capacities Affected

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

Duration

Indefinite

Start Date

8/17/2018

Registration Capacities Affected

from participating in any offering of a penny stock

Duration

Indefinite

Start Date

8/17/2018

Sanctions

Cease and Desist

Sanctions

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

Amount

$169,000.00

Amount

$35,388.00

Sanctions

Disgorgement

Amount

$412,230.00

Sanctions

Monetary Penalty other than Fines

Sanctions

Prohibition

Previous Registration(s)

th hidden text	th hidden text	Name	Location
IA	06/23/2010 - 08/28/2018	BKS ADVISORS, LLC (CRD#:109065)	SOUTHFIELD, MI

BKS ADVISORS, LLC (CRD#:109065)

SOUTHFIELD, MI

06/23/2010 - 08/28/2018

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Broker

A brokerage firm, also called a broker-dealer, is in the business of buying and selling securities – stocks, bonds, mutual funds, and certain other investment products – on behalf of its customer (as broker), for its own bank (dealer), or both. Individuals who work for broker-dealers - the sales personnel are commonly referred to as brokers.

Investment Adviser

An investment adviser is paid for providing advice about securities to clients. In addition, some investment advisers manage investment portfolios and offer financial planning services.

Disclosures

Disclosures can be customer complaints or arbitrations, regulatory actions, employment terminations, bankruptcy filings and certain civil or criminal proceedings that they were a part of.