LOUISIANA DEPARTMENT OF INSURANCE

THE LOUISIANA DEPARTMENT OF INSURANCE (LDI) HAS DETERMINED THAT MR. WHITE'S FAILURE TO TIMELY REPORT TWO ADMINISTRATIVE ACTIONS IS IN VIOLATION OF LA. R.S. 22:1563 (A). LDI IS IN RECEIPT OF DOCUMENTATION INDICATING THAT ON OCTOBER 17, 2018, THE ARKANSAS SECURITIES COMMISSION FINED MR. WHITE $5,000.00, AND THAT ON NOVEMBER 21, 2019, THE FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) BARRED MR. WHITE FROM ASSOCIATING WITH ANY FINRA MEMBER FIRM IN ANY AND ALL CAPACITIES. THESE ADMINISTRATIVE ACTIONS WERE NOT REPORTED TO THE LDI WITHIN THIRTY DAYS OF THEIR FINALIZATION.

Order

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

$250.00

ORDERED TO PAY A FINE OF TWO HUNDRED AND FIFTY DOLLARS.

MR. WHITE REPORTED THE ARKANSAS CONSENT ORDER AND FINRA AWC IN THE FIRM'S ADV PART 1 AND PART 2 DISCLOSURE BROCHURE, WHICH WAS SUBMITTED VIA THE IARD SYSTEM, SHORTLY AFTER EACH ACTION WAS FINALIZED. THE IARD SYSTEM REPORTS THE ACTION TO EACH STATE SECURITIES DEPARTMENT IN WHICH MR. WHITE IS REGISTERED AND IT WAS HIS UNDERSTANDING THAT THE ACTIONS WERE PROPERLY REPORTED TO ALL STATE AGENCIES.

FINRA

Without admitting or denying the findings, White consented to the sanction and to the entry of findings that he refused to appear for on-the-record testimony that was requested by FINRA in connection with an investigation into the circumstances surrounding his termination from his member firm. The findings stated that the firm filed a Form U5 stating that it had discharged White for failing to adequately disclose outside activities including his relationship to company business.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All Capacities

Indefinite

11/21/2019

AT THE TIME OF FINRA'S REQUEST FOR THE SECOND ON-THE-RECORD INTERVIEW, MR. WHITE WAS NO LONGER EMPLOYED BY A FINRA MEMBER FIRM AND HAD NO PLANS TO BECOME REGISTERED AS A REGISTERED REPRESENTATIVE OF A FINRA MEMBER FIRM. THEREFORE, HE DECLINED TO APPEAR AND ACCEPTED A BAR FROM ASSOCIATING WITH ANY FINRA MEMBER FIRM IN ANY AND ALL CAPACITIES.

Arkansas

White organized five real estate business ventures which he disclosed as business activities. The Staff determined that the five real estate business ventures should have been classified as private securities transactions and not other business activities. These ventures were organized and promoted by White and included several of White's clients as investors. As such, the business ventures were improperly classified as simple rental property positions on his form U-4.

Consent

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

$5,000.00

Undertaking

White shall pay a civil penalty of $5,000.00 and shall commence the necessary efforts to ensure that the subject real estate business ventures described are registered as securities or found to be exempt from registration by the Staff and all necessary related filing and notice requirements are met.

ADVISOR DISCLOSED ALL DETAILS PERTAINING TO HIS OWNERSHIP IN EACH BUSINESS. COMPLIANCE SUPERVISION INCORRECTLY CLASSIFIED PRIVATE SECURITIES TRANSACTIONS AS SIMPLE REAL ESTATE AND APPROVED EACH AS OUTSIDE BUSINESS ACTIVITIES.

MassMutual

Discharged

Registered Representative failed to adequately disclose outside activities including their relationship to company business.