FINRA

Without admitting or denying the findings, David consented to the sanctions and to the entry of findings that he falsified his customers’ account profile information. The findings stated that David falsely increased the net worth and liquid net worth of eight customers and changed the risk tolerance of one customer’s account in his member firm’s systems for maintaining account profile information for brokerage accounts. David did this in order to circumvent the firm’s solicitation restrictions and concentration limits for non-investment grade, fixed-income securities. By falsifying this information, David made the customers eligible for purchases of non-investment grade, fixed-income securities, for which they would have otherwise been ineligible under the firm’s procedures. As a result, David caused the firm to maintain inaccurate books and records. The findings also stated that David overconcentrated three customers in non-investment grade, fixed income securities. Specifically, David concentrated between approximately 32.72 and 71.18 percent of these customers’ liquid net worth in non-investment grade, fixed-income securities, which was inconsistent with the customers’ investment objectives and risk tolerances. These securities entailed a high degree of risk, including the risk of default, and subjected the customers to a substantial risk of loss. The findings also included that David exercised discretion in eight customers’ accounts without prior written authorization.

Acceptance, Waiver & Consent(AWC)

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

$15,000.00

Suspension

All capacities

20 months

4/18/2022

12/17/2023

CLIENT ALLEGED, INTER ALIA, FAILURE TO FOLLOW INSTRUCTIONS WITH RESPECT TO INVESTMENTS MADE IN HIS MANAGED ACCOUNT 2017-2019 DAMAGES UNSPECIFIED

$60,000.00

Client alleged, inter alia, misrepresentation with respect to corporate bond investments - 9/24/2014 to 02/29/2020

$183,000.00

$85,000.00

Client verbally alleged, inter alia, unsuitability with respect to investments. - April 2015- March 2019

$35,000.00

Client alleged, inter alia, unauthorized trading with respect to investments - October 2010 to May 2019.

$800,000.00

Claimants allege, inter alia, unsuitability with respect to investments Mar 2017 - Mar 2019

$200,000.00

MSSB

Discharged

Allegations related to registered representative entering inaccurate client profile information relative to bond-related transactions and concerns that some of those transactions were not confirmed immediately beforehand.