Texas

The Securities Commissioner enters this order against Respondent in connection with Respondent's sales of promissory notes in companies in which Respondent had a personal interest. Respondent did not completely disclose his role in the companies or his private securities transactions to Respondent's firm. Respondent sold the promissory notes to brokerage clients of Respondent's. Respondent subsequently failed to disclose the fact that the promissory notes were sold to brokerage clients to his current firm and failed to update his Form U4 to accurately disclose all outside business activities. Respondent has agreed in an undertaking executed with the Securities Commissioner to pay three-hundred sixty-six thousand, two-hundred and eighteen dollars ($366,218.00), an amount totaling the sum of promissory notes sold, to all investors in the promissory notes. Respondent has also agreed to a suspension from soliciting new clients for a period of 1 year and to be placed on probation for a period of 5 years and comply with the terms of the probation contained herein. It is therefore ORDERED that Respondent is hereby SUSPENDED from soliciting new accounts on behalf of Vere for a period of 1 year. It is further ORDERED that Respondent is hereby PLACED ON PROBATION for a period of 5 years. It is further ORDERED that Respondent COMPLY with the terms of the Undertaking incorporated by reference herein in which Respondent undertakes and agrees to pay $366,218 an amount totaling the sum of promissory notes sold to investors of Missco.

Order

Suspension

Soliciting new accounts on behalf of Vere Global Wealth Management

1 year

10/31/2019

10/30/2020

Undertaking

Probation

It is therefore ORDERED that Respondent is hereby SUSPENDED from soliciting new accounts on behalf of Vere for a period of 1 year. It is further ORDERED that Respondent is hereby PLACED ON PROBATION for a period of 5 years. It is further ORDERED that Respondent COMPLY with the terms of the Undertaking incorporated by reference herein in which Respondent undertakes and agrees to pay $366,218.00 an amount totaling the sum of promissory notes sold to investors of Missco.

FINRA

Without admitting or denying the findings, LeBlanc consented to the sanction and to the entry of findings that he failed to disclose several outside business activities to his member firm and provided inaccurate information about an outside business activity to it. The findings stated that LeBlanc engaged in private securities transactions without the knowledge or approval of the firm. The findings also stated that LeBlanc misused customer funds by applying a customer's money to an investment other than the one he represented to her. LeBlanc sold a promissory note from one customer to a second customer for $23,000. The second customer was led to believe by LeBlanc that she was investing in a coffee shop. Instead, LeBlanc returned $3,000 to the customer and invested the remaining $20,000 in a real estate investment company, without informing her of the change of investment. FINRA found that LeBlanc misused customer funds by commingling personal and customer funds in various bank and brokerage accounts. LeBlanc frequently commingled funds in order to pay bills for the various entities and his own personal expenses. FINRA also found that LeBlanc did not provide documents to FINRA that were requested after he testified that they were in his possession.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All Capacities

Indefinite

6/29/2017

Girard Securities, Inc.

Discharged

The firm was made aware of a previously under-disclosed OBA. An investigation revealed that the RR was also participating in the OBA in a manner inconsistent with Rules 3040 and 3280.

While employed with Girard Securities, the firm was made aware of a previously under-disclosed OBA. After Girard's internal investigation, they deemed that I participated in that OBA in a manner inconsistent with Rules 3040 and 3280. This OBA involves my partial ownership in Alpha Grounds Coffee, LLC. It is a local, neighborhood coffee shop that, as I mentioned to friends and family, they asked if they could financially invest in. In a momentary lapse of judgment and not thinking through the possible ramifications, I allowed their investment and failed to disclose to my b/d. No client complaints occurred, no client lost any money, each client has signed a "hold-harmless" agreement stating that they understood that this investment was not affiliated with my former broker/dealer. I think that my spotless, 20 year record in the financial industry speaks for itself. This one incident was just a momentary lapse in judgment on my part.

CUSTOMER ALLEGES THAT THE RR MISREPRESENTED THE CUSTOMER'S NET WORTH WITHOUT THE CUSTOMER'S KNOWLEDGE SO THAT THE CUSTOMER WOULD BE CONSIDERED AN "ACCREDITED INVESTOR" AND PERMITTED TO PURCHASE CERTAIN CERTIFICATES OF DEPOSIT.

$135,267.78

IT IS UNFORTUNATE THAT DUE TO EVENTS BEYOND MY CONTROL THAT THIS SITUATION HAS GOTTEN TO THIS POINT. I HAVE COOPERATED WITH AND HAVE PROVIDED THE REGULATORY AGENCIES WITH ALL OF THE INFORMATION THAT THEY HAVE REQUESTED AND HAVE DONE SO IN A TIMELY MANNER. GIRARD CONTACTED TEXAS STATE SECURITIES BOARD AND THEY INFORMED GIRARD THAT THE CASE WAS CLOSED WITH NO ACTION.

CLIENT COMPLAINED TO THE TEXAS STATE SECURITIES BOARD ABOUT TWO CDS PURCHASED THROUGH THE STANFORD GROUP IN 2008 AND 2009 AND ALLEGES POSSIBLE KNOWLEDGE BY THE REPRESENTATIVE OF IMPROPRIETIES ON BEHALF OF STANFORD GROUP WITH RESPECT TO ITS CDS.

$1,100,000.00

I HAVE ALWAYS MADE IT A PRIORITY TO ACT IN THE BEST INTEREST OF EACH CLIENT. IN NO WAY DO I FEEL I MISREPRESENTED ANY INVESTMENTS, AS I HAVE ALWAYS DESCRIBED EACH INVESTMENT VEHICLE THAT I HAVE RECOMMENDED AS I UNDERSTOOD THEM TO BE, BOTH BY MY OWN DUE DILIGENCE AND BY THE "VETTING PROCESS" OF MY BROKER/DEALER. IT IS REGRETTABLE THAT THIS SITUATION HAS REACHED THIS POINT.

CUSTOMER ALLEGES THAT A CD PURCHASED FROM MR. LEBLANC THROUGH STANFORD GROUP WAS MISREPRESENTED AND THAT CUSTOMER WAS NOT AN ACCREDITED INVESTOR. THE CUSTOMER ALLEGES A LOSS OF $59,878.

$59,878.00

IT IS VERY REGRETTABLE THAT THIS SITUATION HAS COME TO THIS. I PROVIDED [CUSTOMER], AS I HAVE TRIED TO PROVIDE ALL OF MY CLIENTS, TOP-NOTCH CLIENT SERVICE AND DEDICATION, AND INVESTMENT ADVICE WHICH I FELT WOULD HELP HIM BEST ACHIEVE HIS RETIREMENT GOALS AND OBJECTIVES. IT IS UNFORTUNATE THAT EVENTS BEYOND MY CONTROL HAVE LED US TO THIS POINT.