New Jersey Bureau of Securities

VILORD ENGAGED IN DISHONEST OR UNETHICAL BUSINESS PRACTICES. VILORD IS THE SUBJECT OF AN ORDER OF A SELF-REGULATORY ORGANIZATION EXPELLING HIM FROM A SELF-REGULATORY ORGANIZATION. VILORD FILED A FALSE APPLICATION WITH THE BUREAU. VILORD MADE FALSE OR MISLEADING FILINGS WITH THE BUREAU.

Order

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

$35,000.00

Denial

Revocation

The investment adviser representative registrations of Thomas J. Vilord be REVOKED and DENIED. The agent registration of Thomas J. Vilord be REVOKED. Vilord is denied all exemptions contained in N.J.S.A. 49:3-50 subsections (a) paragraph 9, 10, and 11 and subsection (b); and further the exemptions to the registration requirements provided by N.J.S.A. 49:3-56(b), N.J.S.A. 49:3-56(c) and N.J.S.A. 49:3-56(g) are hereby revoked as to Thomas J. Vilord.

Client alleges rep did not give her the contract to Allianz annuity. Contract [Account Number].

$17,000.00

$1,477.13

FINRA

Without admitting or denying the findings, Vilord consented to the sanction and to the entry of findings that he participated in undisclosed private securities transactions involving more than $347,500 in unregistered corporate debenture notes sold to customers of his member firm. The findings stated that Vilord assisted these customers in making the investments by, among other things, preparing transaction paperwork and providing the customers with information about the company issuing the notes. Vilord did not give prior notice, oral or written, to his firm that he would be participating in the offering. The findings also stated that Vilord lacked a reasonable basis to recommend the notes because he failed to conduct adequate due diligence on the offering. Vilord's knowledge of the company was limited to his conversations with the company's owner, information contained on the company's website, and Google searches. Although Vilord was familiar with some sources of the company's revenue, he did not know actual revenue and debt amounts, and failed to review the company's financial statements. The findings also included that Vilord willfully failed to timely disclose customer complaints related to the sales on his Form U4 and made false statements about one complaint in a Form U4 filing. FINRA found that Vilord provided false statements regarding the same complaint in his written response to FINRA request for information and documents concerning the offering and a customer's complaint.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All Capacities

Indefinite

12/22/2016

This settlement includes a finding that Vilord willfully omitted to state a material fact and/or willfully misrepresented a material fact on a Form U4, and that under Section 3(a)(39)(F) of the Securities Exchange Act of 1934 and Article III, Section 4 of FINRA's By-Laws, this omission and/or misrepresentation makes him subject to a statutory disqualification with respect to association with a member.

BREACH OF CONTRACT, FRAUD.

$75,000.00

$65,068.97

RECOMMENDATION OF HIGH RISK NOTE THAT WAS UNSUITABLE

$25,000.00

SAGEPOINT FINANICAL

Permitted to Resign

ADVISOR FAILED TO NOTIFY FIRM REGARDING A WRITTEN COMPLAINT THAT WAS FILED AGAINST HIM.

I RECEIVED A CALL FROM OUR LEGAL DEPARTMENT ON A THURSDAY REGARDING THE ARBITRATION. THAT FOLLOWING MONDAY A FIRM AUDITOR CAME TO MY OFFICE. WITH MY OSJ AND THE AUDITOR WE WENT THROUGH EMAILS TO SEE IF A COMPLAINT WAS RECEIVED PRIOR TO NOTIFICATION OF THE ARBITRATION. THERE WAS NOTHING. I WAS UNAWARE OF THE ISSUE UNTIL THE ARBITRATION WAS RECEIVED BY THE FIRM AND SOMEONE FROM LEGAL CALLED ME. THERE WAS NO COMPLAINT FOR ME TO FORWARD TO THE FIRM.

VIOLATION OF 10(B) AND 20(A) OF SECURITIES EXCHANGE ACT OF 1934

$75,000.00

$24,999.00

I DID NOT SELL THIS PRODUCT TO THE CLIENT. IT WAS AT ONE OF MY CLIENT APPRECIATION NIGHTS THAT I HOLD 3-4 TIMES A YEAR THAT THE ATTORNEY AND CLIENT CASUALLY MET. AS USUAL I INVITED SOME PEOPLE IN MY BUSINESS NETWORKING GROUP AS WELL AS CLIENTS TO THIS EVENT. MY GROUP INCLUDES EVERYONE FROM ATTORNEYS TO LANDSCAPERS. BUT UNBEKNOWNST TO ME THE ESTATE PLANNING ATTORNEY SOLICITED THE CLIENT FOR PRIVATE FUNDING. AT NO TIME WAS I AWARE OF THIS TRANSACTION NOR DID I PROFIT FROM IT. AN AUDIT BY SAGEPOINT FOUND NO SOLITICATION OR RECOMMENDATIONS FROM ME TO THE CLIENT REGARDING THIS PRODUCT. THEY REVIEWED MY BANK STATEMENTS BOTH BUSINESS AND PERSONAL FOR SEVERAL YEARS TO DETERMINE IF I HAD RECEIVED ANY FUNDS. THEY FOUND NOTHING. I HAD NO KNOWLEDGE OF WHAT THE ATTORNEY WAS DOING OR SAYING AFTER THEY MET AT THE EVENT.

REP DID PROPERLY ADVISE OF THE RISKS OF INVESTMENT

$20,000.00

REP DENIES ALL ALLEGATIONS. CLIENT WAS UPSET BECAUSE REP ASK HIM TO FIND ANOTHER FINANCIAL ADVISOR.

CLIENT ALLEGES FINANCIAL ADVISOR SOLD HER AN ANNUITY AND SOMEONE ALLEDEDLY CHANGED THE DEATH BENEFIT BOX WITHOUT HER AUTHORIZATION. DAMAGES UNSPECIFIED. ESTIMATED TO BE OVER $5,00.

MORGAN STANLEY REVIEWED [CUSTOMER'S] COMPLAINT AND DETERMINED THAT IT HAD NO MERIT.

MORGAN STANLEY AND CO. INC.

Discharged

FAILURE TO FOLLOW MANAGEMENT DIRECTIVES PERTAINING TO EMPLOYEE PROSPECTING ACTIVITIES.