FINRA

Without admitting or denying the findings, Brooks consented to the sanction and to the entry of findings that she engaged in private securities transactions without providing prior notice to or obtaining approval from her member. The findings stated that Brooks solicited investors to purchase more than $1.77 million in securities in a purported real estate investment fund and in a company representing itself as a structured cash flow investment company. Brooks, through an entity that she worked with as an outside business, solicited investors, over half of whom where customers of her firm, to invest $906,497 in the fund's promissory notes. Later, the fund filed a voluntary Chapter 11 bankruptcy petition. The U.S. District Court for the Southern District of Florida issued final judgments against, among others, the fund and its former owner. Those judgments required the fund and its owner to, among other things, disgorge their ill-gotten gains and pay a civil penalty. In addition, Brooks sold $866,895 in company purchase agreements to investors, most of whom were firm customers. Later, the investment company ceased business, owing nearly $300 million in unpaid investor payments. In a subsequent indictment, the U.S. charged the investment company and its owner with conspiracy to engage in mail and wire fraud related to the investment company's operations.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All capacities

Indefinite

6/9/2020

Statement of claim alleges that the representative recommended that the complainant invest her IRA monies in a fraudulent Ponzi scheme

$118,000.00

$75,000.00

Signator Investors, Inc.

Voluntary Resignation

The Firm was investigating the representative to determine her level of involvement in the sale of unregistered securities.