FINRA

Without admitting or denying the findings, Donnelly consented to the sanction and to the entry of findings that he participated in a private securities transaction by facilitating the sale of $250,000 of a security to a customer without providing prior written notice to his member firm. The findings stated that Donnelly introduced the customer to the president of a company seeking investments in limited partnership units. The limited partnership units were securities. After making the initial introduction, Donnelly provided to the customer the private placement memorandum for the investment and a presentation about the company. Donnelly also discussed with the company how the customer should make payment. Thereafter, the customer invested $250,000 in the company. Even after the customer made his investment in the company, Donnelly continued to act as an intermediary between the customer and the company. Donnelly did not receive any commissions or other compensation for his activities. Donnelly failed to provide prior written notice to the firm to participate in the company's sale of limited partnership units to the customer, and his participation in the transaction was outside the regular course and scope of his employment with the firm. The findings also stated that Donnelly used his personal email account to communicate with the customer about securities transactions. Donnelly also used text messaging on his personal cell phone to communicate with another firm customer about securities transactions, including the liquidation of several securities that the customer held at the firm. Donnelly did not forward his emails or text messages to the firm for review or retention. As a result, Donnelly caused the firm to fail to retain the emails and text messages among its books and records.

Acceptance, Waiver & Consent(AWC)

Suspension

All Capacities

Four Months

7/5/2022

11/4/2022

In light of Donnelly's financial status, no monetary sanction has been imposed.

Claimants elected to invest in GPB through joint Representatives in 2015 and now claim, after suspension of distributions, that the investment was not suitable.

$100,000.00

$55,000.00

$25,319.00

Tax

$32,494.00

Tax

Compromise

Satisfied/Released

$100,891.00

Tax

$112,625.00

Tax

Gitterman Wealth Management, LLC

Permitted to Resign

Adviser initiated transactions that would have resulted in multiple commissions for a single transaction. Further, ultimate transaction determined to be in excess of permissible non-traded REIT guidelines. Loss of confidence in judgment, permitted adviser to resign after notified of termination.

The first transaction was initiated to ensure a client's funds were applied correctly. It would not have generated a commission as it involved a non-commissionable product in the New Jersey Alternate Benefit Program. When Mr. Donnelly initiated the transaction, information he had indicated it would have been within state limits for non-traded REITs. The transaction was not executed during his employment. Mr. Donnelly denies engaging in any wrongful or unlawful conduct.

$150,480.00

Tax

$18,988.00

Tax

$17,543.00

Tax

$705.00

Civil