Client alleges that the Representative omitted material information and misrepresented the GWG L Bond she purchased in April 2018.

$28,800.00

$14,999.00

Client claims that I misrepresented information about GWG L Bonds. I vigorously deny all allegations. Client was provided with all proper disclosure information, including the prospectus and signed all the required paperwork which included disclosures about the risks and merits of the L Bonds investment. Client also claims history of customer disputes. I have two disputes by one customer which were denied as non-meritorious. Client has been a customer for 17 years with investments in Variable Annuities invested in the market and sophisticated to understand different investment products.

FINRA

GOEL WAS NAMED A RESPONDENT IN A FINRA COMPLAINT ALLEGING THAT HE FALSIFIED CUSTOMER DOCUMENTS BY OBTAINING AND MAINTAINING PRE-SIGNED CUSTOMER FORMS. THE COMPLAINT ALLEGES THAT GOEL, WHILE TRANSFERRING CUSTOMER ACCOUNTS TO HIS MEMBER FIRM FROM HIS FORMER FIRM, OBTAINED CUSTOMER SIGNATURES ON ONE SET OF DOCUMENTS AND THEN COPIED THE SIGNATURE PAGES AND USED THEM FOR MULTIPLE SETS OF DOCUMENTS FOR THE SAME CUSTOMER. GOEL MAINTAINED PRE-SIGNED ACCOUNT TRANSFER DOCUMENTS, AS WELL AS OTHER DOCUMENTS REQUIRING A CUSTOMER'S SIGNATURE, IN HIS FILES, THROUGHOUT HIS EMPLOYMENT WITH THE FIRM. AT TIMES, GOEL SUBMITTED FORMS TO THE FIRM FOR PROCESSING UTILIZING THE PRE-SIGNED DOCUMENT COMBINED WITH LATER-COMPLETED PORTIONS OF THE DOCUMENT.

Decision & Order of Offer of Settlement

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

$10,000.00

Suspension

ALL CAPACITIES

SIX MONTHS

8/17/2015

2/16/2016

WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GOEL CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE FALSIFIED CUSTOMER DOCUMENTS BY OBTAINING AND MAINTAINING PRE-SIGNED CUSTOMER FORMS. THE FINDINGS STATED THAT GOEL, WHILE TRANSFERRING CUSTOMER ACCOUNTS TO HIS MEMBER FIRM FROM HIS FORMER FIRM, OBTAINED CUSTOMER SIGNATURES ON ONE SET OF DOCUMENTS AND THEN COPIED THE SIGNATURE PAGES AND USED THEM FOR MULTIPLE SETS OF DOCUMENTS FOR THE SAME CUSTOMER. GOEL MAINTAINED PRE-SIGNED ACCOUNT TRANSFER DOCUMENTS, AS WELL AS OTHER DOCUMENTS REQUIRING A CUSTOMER'S SIGNATURE, IN HIS FILES, THROUGHOUT HIS EMPLOYMENT WITH THE FIRM. AT TIMES, GOEL SUBMITTED FORMS TO THE FIRM FOR PROCESSING UTILIZING THE PRE-SIGNED DOCUMENT COMBINED WITH LATER-COMPLETED PORTIONS OF THE DOCUMENT. FINE PAID IN FULL ON JUNE 16, 2015.

WITHOUT ADMITTING OR DENYING THE ALLEGATIONS GOEL CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS. FINE PAID IN FULL ON JUNE 16, 2015.

LPL FINANCIAL LLC

Discharged

VIOLATION OF THE FIRM'S DOCUMENT SIGNATURE POLICY.

FINRA

NASD RULE 2110: WITHOUT THE CUSTOMER'S KNOWLEDGE OR CONSENT, GOEL PLACED A CUSTOMER'S SIGNATURE ON TWO FIRM DOCUMENTS IN CONNECTION WITH TWO ANNUITY PURCHASES. GOEL AND AN ELDERLY CUSTOMER MET AT HIS MEMBER FIRM'S BANK BRANCH TO DISCUSS HER INVESTMENT ACCOUNTS, WHICH INCLUDED TWO MUTUAL FUNDS. IN THE COURSE OF THESE DISCUSSIONS, GOEL RECOMMENDED THAT THE CUSTOMER SELL THE MUTUAL FUNDS AND INVEST THE PROCEEDS IN AN EQUITY-INDEXED ANNUITY AND A VARIABLE ANNUITY. AS PART OF ITS SUPERVISORY REVIEW, THE FIRM REQUIRED REGISTERED REPRESENTATIVES TO PROVIDE A WRITTEN STATEMENT DESCRIBING THE RATIONALE FOR RECOMMENDING THAT A CUSTOMER SELL A PACKAGED PRODUCT, INCLUDING A MUTUAL FUND, AND REPLACE IT WITH ANOTHER PACKAGED PRODUCT, INCLUDING AN ANNUITY. WITHOUT THE CUSTOMER'S KNOWLEDGE, AUTHORIZATION OR CONSENT, GOEL PLACED THE CUSTOMER'S SIGNATURE ON TWO STATEMENTS HE PREPARED IN CONNECTION WITH PROVIDING A RATIONALE FOR THE RECOMMENDATIONS; UNBEKNOWNST TO GOEL, THE FIRM DID NOT REQUIRE A CUSTOMER'S SIGNATURE ON THE REGISTERED REPRESENTATIVE'S STATEMENT OF RATIONALE.

Acceptance, Waiver & Consent(AWC)

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

$7,500.00

Suspension

ANY CAPACITY

ONE MONTH

9/6/2011

10/5/2011

WITHOUT ADMITTING OR DENYING THE FINDINGS, GOEL CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, HE IS FINED $7,500 AND SUSPENDED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY FOR ONE MONTH. THE SUSPENSION IS IN EFFECT FROM SEPTEMBER 6, 2011, THROUGH OCTOBER 5, 2011.

CLIENT ALLEGES FORGERY AND SUITABILITY IN REGARDS TO A VARIABLE ANNUITY INVESTMENT. ACTIVITY DATES 11/9/07-11/9/07.

$12,642.92

CLIENT ALLEGES REGISTERED REPRESENTATIVE MISREPRESENTED THE ANNUITY SHE PURCHASED IN NOVEMBER, 2007.

COMPLAINT DENIED AS NON-MERITORIOUS.