FINRA

Without admitting or denying the findings, Seymour consented to the sanctions and to the entry of findings that he failed to notify his member firms about the full nature of his participation in an OBA. The findings stated that before becoming associated with any FINRA member firm, Seymour provided tax preparation and trust administration services through his wife's tax and estate business. Seymour also served as co-trustee of a trust. Both the trust and its beneficiaries later became customers of Seymour at his firms. Upon associating with each of the firms, Seymour sought to continue working for his wife's tax and estate business. In considering Seymour's requests for approval of his OBA, each firm placed restrictions on the scope of his participation in the activity. Seymour disclosed to the first firm that he served as co-trustee of a trust, and that he worked for his wife's tax and estate business. The firm approved Seymour's work for his wife's business as an OBA but prohibited him from continuing to serve as co-trustee for the trust. When Seymour later became associated with the second firm, he again requested approval to work for his wife's business but did not disclose to the firm that he provided trust administration services, including performing the duties of a co-trustee for the trust, through his wife's business. Instead, Seymour's written request for approval described his responsibilities for his wife's business merely as tax preparation. The firm subsequently approved Seymour's work for his wife's business as an OBA but prohibited him from serving as a trustee or maintaining billpaying authority over any third-party bank account. Seymour exceeded the scope of his approved OBA while he was associated with each firm. Seymour, at the direction of the remaining co-successor trustee, continued to perform the duties of a co-trustee for the trust, even though both firms had prohibited him from serving as a trustee. In addition, Seymour failed to comply with the second firm's prohibition against having bill-paying authority over any third-party account. Using his check-writing authority for the trust's bank account, Seymour issued checks, including checks to compensate himself for the services he provided to the trust. In so doing, Seymour engaged in OBAs without providing full and accurate prior written notice to his firms of those activities. The findings also stated that Seymour submitted compliance questionnaires to one of the firms, in which he falsely attested that he had not participated in OBAs that he had not disclosed to the firm.

Acceptance, Waiver & Consent(AWC)

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

$5,000.00

Suspension

All capacities

Two months

12/5/2022

2/4/2023

STEWARD PARTNERS INVESTMENT ADVISORY, LLC

Discharged

Terminated for various policy violations, including conducting firm business through an outside email address, acting in an unapproved capacity for a client, and reuse of blank, signed forms for another client.

MY SEPARATION WITH MY FORMER FIRM RESULTED FROM A CLIENT APPOINTING ME AS CLIENT'S SOLE POWER OF ATTORNEY, WITHOUT MY KNOWLEDGE OR CONSENT; I ONLY LEARNED OF APPOINTMENT AFTER CLIENT FELL INTO A COMA AND ONLY ACTED ON CLIENT'S BEHALF AS REASONABLE NECESSARY TO ENSURE HEALTH AND WELLBEING OF CLIENT.

Raymond James Financial Services, Inc.

Discharged

Terminated for various policy violations, including conducting firm business through an outside email address, acting in an unapproved capacity for a client, and reuse of blank, signed forms for another client.