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REGISTRANT FAILED TO FOLLOW FIRM PROCEDURES REGARDING THE MAINTENANCE OF BOOKS AND RECORDS. REGISTRANT MAINTAINED ACCOUNT DOCUMENTS CUSTOMERS HAD SIGNED IN BLANK IN THREE CLIENT FILES. REGISTRANT DID NOT PROMPTLY SUBMIT CHECKS RECEIVED FROM CLIENTS TO THE FIRM ON TWO OCCASIONS. REGISTRANT'S DISCHARGE WAS NOT DUE TO ANY CUSTOMER COMPLAINTS OR ALLEGATIONS. THE FIRM'S INVESTIGATION DID NOT REVEAL HARM TO ANY CUSTOMER.
Broker Comment
Registrant finished the last semester of law school during this time. In two instances the "in blank" forms were transfer forms not able to be used by the client's current company. At the time of signing the forms, the clients did not have a statement from the current provider with the necessary information with them in order to complete the transfer form. Both were signed for client convenience and in both instances the clients were very well acquainted with the registrant. The third form was a tiered annuity disclosure. Registrant downloaded a tier 1 disclosure when a tier 2 was needed. Incomplete forms were filed in the client files. The checks were received by Registrant on Friday evening and Saturday afternoon respectively and not processed and forwarded until Tuesday when firm policy required "24 hours." An official on the record hearing was conducted in Washington DC by the Certified Financial Planners Board and no discipline actions were taken. See www.cfp.net and search ID#138609. Registrant also has passed the character and fitness review board for both Kentucky and Texas Bars and has been admitted to the practice of law in both jurisdictions.
License(s)
The broker is not currently registered with any state or SRO.
A brokerage firm, also called a broker-dealer, is in the business of buying and selling securities – stocks, bonds, mutual funds, and certain other investment products – on behalf of its customer (as broker), for its own bank (dealer), or both. Individuals who work for broker-dealers - the sales personnel are commonly referred to as brokers.
IA
Investment Adviser
An investment adviser is paid for providing advice about securities to clients. In addition, some investment advisers manage investment portfolios and offer financial planning services.
Disclosures
Disclosures can be customer complaints or arbitrations, regulatory actions, employment terminations, bankruptcy filings and certain civil or criminal proceedings that they were a part of.
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Disclosures can be customer complaints or arbitrations, regulatory actions, employment terminations, bankruptcy filings and certain civil or criminal proceedings that they were a part of.