Time frame: TBD Allegations: Claimants allege that the FA recommended unsuitable and speculative investments, including master limited partnerships in energy sector, when claimants were conservative investors.

Time frame: September 2015 to September 2020 Allegations: Claimants' counsel alleges unsuitability and overconcentration of certain investments, and that such investments resulted in principal losses. Claimants' counsel further alleges misrepresentation and unauthorized trading with respect to the handling of Claimants' investment accounts.

$150,000.00

FINRA

Respondent Sommo failed to respond to FINRA requests for information.

Letter

Bar (Permanent)

All capacities

Indefinite

4/4/2022

Pursuant to FINRA Rule 9552(h) and in accordance with FINRA’s Notice of Suspension and Suspension from Association letters dated December 31, 2021 and January 24, 2022, respectively, on April 4, 2022, Sommo is barred from association with any FINRA member in all capacities. Sommo failed to request termination of his suspension within three months of the date of the Notice of Suspension; therefore, he is automatically barred from association with any FINRA member in all capacities.

Time Frame: December 2, 2015 to January 31, 2020 What were the allegations against the individual? The client alleges she was placed in unsuitable securities and was overconcentrated in the MLP energy sector. The alleged damages are estimated to be in excess of $5,000.00

$30,000.00

CLIENT STATES HE WAS NOT INFORMED THAT HE COULD LOSE PRINCIPAL OR THAT HE WOULD HAVE PENALTIES FOR EARLY WITHDRAWALS PRIOR TO PURCHASING A VARIABLE ANNUITY. CLAIM AMOUNT BELIEVED TO EXCEED $5,000. (10/01/2007 - 09/15/2008)

CLIENTS THOUGHT THEY HAD LOST PRINCIPAL DUE TO MARKET FLUCUATION; HOWERVER, PRINCIPAL IS GUARANTEED IN THE FORM OF FUTURE INCOME REGARDLESS OF MARKET PERFORMANCE.

THIS COMPLAINT AROSE OUT OF THE SALE OF AN ARS THAT WAS MADE PRIOR TO THE WIDESPREAD ILLIQUIDITY IN THE ARS MARKET THAT OCCURRED IN FEBRUARY 2008.

$25,000.00

THIS MATTER INVOLVES THE SALE OF AUCTION RATE SECURITIES (ARS). THE TRANSACTION(S) AT ISSUE TOOK PLACE BEFORE MID-FEBRUARY 2008, WHEN THE ARS MARKET SUFFERED WIDESPREAD AUCTION FAILURES AND ILLIQUIDITY. THE FINANCIAL ADVISOR DID NOT CAUSE, CONTRIBUTE OR HAVE ANY CONTROL WHATSOEVER OVER THESE MARKET EVENTS. THE FIRM REACHED AGREEMENT WITH CERTAIN OF ITS REGULATORS, PURSUANT TO WHICH IT REPURCHASED ARS FOR THEIR FULL PAR VALUE FROM CERTAIN CLIENTS, INCLUDING THE INSTANT CLIENT, WHETHER THEY COMPLAINED OR NOT. THE FINANCIAL ADVISOR WAS NOT A PARTY TO THAT AGREEMENT, DID NOT MAKE ANY PAYMENTS TO THE CLIENT, AND WAS NOT ASKED TO AND DID NOT CONTRIBUTE TO THE REPURCHASE AMOUNT. THE SETTLEMENT AMOUNT IN ITEM 11 ABOVE REFLECTS THE PAR VALUE OF THE REPURCHASED ARS, AS REQUIRED BY FINRA REGULATORY NOTICE 09-12.