FINRA

Without admitting or denying the findings, Berry consented to the sanctions and to the entry of findings that he participated in private securities transactions involving customers without providing prior written notice to his member firms or receiving approval from them. The findings stated that Berry's customers invested $517,410 in oil and gas wells through a series of securities offerings. These customers were all either pre-existing clients or family members of existing clients of Berry's advisory firm. Berry met with and made each customer aware of the oil and gas securities offerings, discussed the investments with each customer, and introduced each customer to a colleague who had visited some of the oil and gas wells to conduct due diligence. For each of the customers, Berry received $2,000, totaling $8,000.

Acceptance, Waiver & Consent(AWC)

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

$5,000.00

Disgorgement

$8,000.00

Suspension

All capacities

Six months

6/17/2024

12/16/2024

When making the initial recommendations, Respondents affirmatively represented to Claimants that the investments were "safe" and consistent with their investment objectives of generating income with the ability to preserve principal. As set forth above, at the Claimants' stage of life, they were not in a position to recover money loss. To this end, Respondents represented that the Resolute/Petrorock Investments were non-correlated alternatives to the stock market, which would not experience volatility. Respondents further touted the so-called tax benefits of investing in oil and gas securities structured like the Resolute/Petrorock Investments. Respondents never balanced the presentation with a discussion of risks. They downplayed the boilerplate disclosure language that appeared in the offering documents as mandatory disclosure language that would have no application.

$473,000.00

PRUCO SECURITIES, LLC

Voluntary Resignation

REGISTERED REPRESENTATIVE MADE UNSUITABLE RECOMMENDATIONS IN CONNECTION WITH THE SALE OF VARIABLE ANNUITIES. ALLEGATIONS CONFIRMED.

PRUDENTIAL ISSUED A "LIFETIME FIVE" BENEFIT BROCHURE ALLEGING 5% GUARANTEE THE FIRST 10 YEARS. UPON FINDING OUT THAT THIS ALLEGATION WAS UNTRUE, I WITHDREW 7 CONTRACTS. NO CLIENT WAS EVER HARMED BY THIS.