Claimant alleges the RR recommended an unsuitable Real Estate Investment Trust (REIT) investment.

$22,500.00

UNITED STATES SECURITIES AND EXCHANGE COMMISSION

The Securities and Exchange Commission ("Commission") deems it appropriate and in the public interest that public administrative proceedings be, and hereby are, instituted pursuant to Section 15(b) of the Securities Exchange Act of 1934 ("Exchange Act") and Section 203(f) of the Investment Advisers Act of 1940 ("Advisers Act") against Matthew O. Clason. The Commission finds that: On September 1, 2020, the Commission filed SEC. v. Clason, 3:20-cv-01279, in which the Commission alleges that Clason misappropriated hundreds of thousands of dollars from a client of the investment adviser and broker-dealer firms with which he was associated, in breach of his fiduciary duty to his client. On May 12, 2021, Clason pled guilty to criminal conduct relating to certain matters alleged in the Commission's Complaint in violation of 18 U.S.C. § 1343 before the United States District Court for the District of Connecticut, in United States v. Matthew Clason, Crim. No. 3:21-CR-66. In connection with that plea, Respondent admitted the certain facts set forth in the Information filed in the Criminal Action.

Order

Bar (Permanent)

broker, dealer, investment adviser, municipal securities dealer, municipal advisor, transfer agent, or NRSRO

Indefinite

8/17/2021

Participating in any offering of a penny stock

Indefinite

8/17/2021

Penny Stock Bar

The former customer alleged she did not authorize the investment and her signature was forged on account opening paperwork relating to the purchase of a non-traded REIT in March 2015.

Claimant alleges Mr. Clason converted monies from Claimant at some point during the 2015-2020 time period.

$2,500,000.00

$1,000,000.00

Customers allege that the registered representative misrepresented overall investment strategy and recommended investments which were unsuitable. Time period of claim: June 2018 - March 1, 2021

$5,000.00

$12,965.00

FINRA

Without admitting or denying the findings, Clason consented to the sanction and to the entry of findings that he refused to provide documents and information requested by FINRA in connection with its investigation into the allegations that formed the basis of his termination reported on a Uniform Termination Notice for Securities Industry Registration (Form U5) submitted by his member firm. The findings stated that the firm filed the Form U5 terminating Clason's registration because he maintained a joint bank account with a firm customer, engaged in liquidations of securities in the customer's firm account, transferred funds to a joint bank account, and withdrew funds.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All capacities

Indefinite

9/17/2020

UNITED STATES SECURITIES AND EXCHANGE COMMISSION

The Securities and Exchange Commission (the "Commission"), for its Complaint against Clason, alleges that this case concerns theft of assets from a retired retail investor by an investment professional. From at least December 2018 to present, investment adviser Matthew O. Clason ("Clason") stole hundreds of thousands of dollars from a client of the investment adviser and broker dealer firms with which he was associated. Clason had cultivated a personal relationship with this client and, during this period, sold securities managed on the client's behalf to fund transfers to a joint bank account held in the names of the client and Clason. Clason then made numerous cash withdrawals from that joint bank account at multiple bank branches. Clason's securities sales, transfer of the proceeds to the joint bank account, and numerous, large cash withdrawals from the joint account were neither known to nor approved by the client. Clason thus exploited a personal relationship with and breached his fiduciary duty to the client to perpetrate his fraud and misappropriate hundreds of thousands of dollars. Through this conduct, Clason has violated and, unless enjoined, will continue to violate Sections 206(1) and 206(2) of the Investment Advisers Act of 1940 (the "Advisers Act"). Based on these violations, the Commission seeks: (1) entry of a temporary restraining order, preliminary injunction, order freezing assets, expedited discovery, an accounting, and order for other equitable relief in the form submitted with the Commission's motion for such relief; (2) entry of a permanent injunction prohibiting Clason from further violations of the relevant provisions of the federal securities laws; (3) disgorgement of the money he misappropriated, plus pre-judgment interest; and (4) imposition of civil monetary penalties based on the egregious nature of Clason's violations.

Judgment Rendered

Disgorgement

$614,840.00

Monetary Penalty other than Fines

Injunction

Undertakings and agreements

LPL Financial LLC

Discharged

Maintained joint bank account with Firm customer, engaged in liquidations of securities in customer's Firm account, transferred funds to joint bank account, and withdrew funds.

Integrated Wealth Concepts

Discharged

Investigating the scope and extent of the Representative's activities as set forth in the Termination Explanation.