FINRA

Ray was named a respondent in a FINRA complaint alleging that he improperly borrowed $50,000 from a customer. The complaint alleges that at the time of the loan, Ray's member firm prohibited borrowing from customers with certain exceptions not applicable here. The loan met none of the exceptions to FINRA Rule 3240 or to the firm's written procedures. Moreover, Ray failed to provide his firm with prior written notice of the loan. The complaint also alleges that Ray falsely certified in an annual compliance questionnaire that he was in compliance with his firm's prohibition against borrowing from customers. The complaint further alleges that Ray provided FINRA with false information and testimony in connection with the investigation of his loan from the customer.

Decision & Order of Offer of Settlement

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

$10,000.00

Suspension

All capacities

18 months

10/2/2017

4/1/2019

Without admitting or denying the allegations, Ray consented to the sanctions and to the entry of findings that contrary to his member firm's written procedures, he borrowed $50,000 from a 70-year-old customer. The findings stated that at the time of the loan, Ray's firm prohibited borrowing from customers with certain exceptions not applicable here and the loan met none of the exceptions to FINRA Rule 3240. Moreover, Ray failed to provide his firm with prior written notice of the loan. The findings also stated that Ray falsely attested in a firm annual compliance questionnaire that he was in compliance with his firm's prohibition customer loans. The findings also included that Ray provided FINRA with false information and testimony in connection with the investigation of his loan from the customer.

Bankruptcy