FINRA

Without admitting or denying the findings, Koehler consented to the sanction and to the entry of findings that he refused to produce information and documents requested by FINRA after it commenced an investigation following receipt of a tip that he had engaged in unsuitable trades in the account of a senior customer. The findings stated that during its investigation, FINRA also reviewed trading in certain other of Koehler's customer accounts, including those associated with a second customer and her senior customer parents. FINRA sought to investigate, among other activity, whether Koehler engaged in unsuitable trading, including short-term mutual fund switching and excessive trading in customer accounts, placed undue influence on the second customer before her death, and failed to disclose his status as a named beneficiary in the second customer's will to his member firm.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All Capacities

Indefinite

6/29/2017

CETERA ADVISOR NETWORKS

Discharged

REPRESENTATIVE TERMINATED FOR ACCEPTING BLANK, SIGNED FORMS FROM CUSTOMERS IN VIOLATION OF FIRM POLICY, SHORT TERM TRADING IN MUTUAL FUNDS AND OTHER CUSTOMER ACCOUNT TRADING ACTIVITY UNDER FIRM REVIEW.

ACCEPTING BLANK, SIGNED DOCUMENT/VIOLATION OF FIRM POLICY- THE DOCUMENT IN QUESTION WAS RECEIVED IN APRIL 2014, IT WAS PARTIALLY COMPLETE, NOT BLANK, AS INDICATED ON THE U5. WHEN I RECEIVED THE FORM, I CALLED THE CLIENT AND COMPLETED IT OVER THE PHONE WITH THEM. ONCE COMPLETE, I FORWARDED IT TO MY OSJ WHERE HE SIGNED IT. I NEVER HEARD ANYTHING ABOUT THE FORM PRIOR TO THIS. AS AN INDEPENDENT REPRESENTATIVE, I'M SUBJECT TO AN ANNUAL AUDIT OF MY FILES. DURING MY AUDITS, THIS FORM WAS NEVER BROUGHT UP. I NEVER HAD ANY PROBLEMS WITH MY FILES AND ALWAYS RECEIVED THE HIGHEST MARKS ON MY AUDITS. SHORT TERM TRADING IN MUTUAL FUNDS AND OTHER ACCOUNT TRADING ACTIVITY- I CAN SAY, WITH GREAT CERTAINTY, THAT I HAVE NO ISSUES WITH MUTUAL FUND TRADING OR ANY OTHER ACCOUNT TRADING ACTIVITY. ALL OF MY CLIENTS WERE INVESTED ACCORDING TO THEIR INVESTMENT OBJECTIVES AND I NEVER RECEIVED ANY INDICATION FROM MY OSJ, OR ANYONE ELSE IN CETERA THAT ANY OF MY TRADING PRACTICES WEREN'T ACCEPTABLE. I NEVER RECEIVED ANY LETTER OF CAUTION, EMAILS, PHONE CALLS, COMPLAINTS OR ANY OTHER COMMUNICATION REGARDING MY BUSINESS, PRIOR TO BEING TERMINATED. IN EARLY JANUARY, I RECEIVED AN AWARD FROM CETERA FOR BEING THE 'TOP RETAIL REP OF THE YEAR' IN MY REGION; IT WAS PRESENTED TO ME BY MY OSJ.

CLIENT ALLEGES REPRESENATIVE TOLD HIM HE WOULD GET HIS ENTIRE PRINCIPAL BACK AT MATURITY.

$31,975.56

$35,000.00

CUSTOMER ALLEGES EXCESSIVE TRADING FROM 2002-2005. JANNEY MONTGOMERY SCOTT LLC HAS DETERMINED THAT THE LIABILITY MAY BE IN EXCESS OF $5,000.00

ALLEGATIONS: UNAUTHORIZED TRADING WITH A CLAIM FOR THE RETURN OF COMMISSIONS ESTIMATED TO BE BETWEEN $15,000 AND $20,000.

$15,000.00

$9,125.26