STATE OF FLORIDA, OFFICE OF FINANCIAL REGULATION

FAILED TO TIMELY AMEND U4 FOR A WRITTEN COMPLAINT

Claimants allege failure to supervise, breach of contract, material misrepresentations, breach of fiduciary duty and lack of suitability in regard to recommendations in alternative products.

$100,000.00

The claimants allege unsuitable recommendations and failure to conduct proper due diligence in regards to transactions in alternative investments. They further allege negligence, as well as misrepresentation and omission of material facts.

$215,386.51

$70,000.00

Customers allege they received a poor recommendation in regards to the purchase of an investment

$25,000.00

$6,000.00

Customers allege lack of suitability, material misrepresentations and failure to conduct proper due diligence in regards to the purchase of alternative investments.

$330,000.00

$75,000.00

Customer alleges lack adequate due diligence, negligence and misrepresentations and omissions of material facts in regards to transactions in a non-traded REIT.

$36,000.00

Customer alleges lack of suitability and adequate due diligence in regards to transactions in non-traded REITs and non-traded BDCs. They further allege negligence, as well as misrepresentations and omissions of material facts.

$40,000.00

$55,000.00

THE CUSTOMER ALLEGES A VIOLATION OF THE FIDUCIARY AND SUITABILITY OBLIGATIONS AS IT RELATES TO THE PURCHASE OF NON-TRADED REITS AND NON-TRADED BDC'S. CUSTOMER FURTHER ALLEGES THEY WERE MISLED ABOUT THE TIME HORIZON AND PROJECTED PERFORMANCE RETURN OF THE INVESTMENTS.

$167,357.75

$41,500.00

The Financial Advisor denies the baseless allegations set forth in the Statement of Claim. The client was thoroughly educated on the risks associated with the investments. The Financial Advisor also denies the baseless allegations set forth in the Statement of Claim of losing 167k which would mean their investments have a zero balance. The Financial Advisor intends to vigorously defend both of these matters.

Customers allege they were sold alternative investments that underperformed.

$160,000.00

The customer alleges a violation of fiduciary and suitability obligations as it relates to the purchase of non-traded REITs, non-traded BDCs and a Variable Annuity contract. They further allege that the representative made material misrepresentations about the risks, profitability and liquidity of the investments.

$250,000.00

$25,000.00

I feel the investments were suitable for my client because they matched her financial goals and needs at the time. We presented multiple investments to the client and educated her on the pros and cons of all of the investment options including lack of liquidity. The client chose the investments she felt matched her needs the best and we moved forward, accordingly. I also dispute the allegation that the client, at the time of the complaint, has suffered a loss in her portfolio.

The claimant alleges lack of suitability, breach of contract and lack of proper due diligence for four alternative investments purchased between April 2014 and April 2016.

$400,000.00

$95,000.00

I feel the investments were suitable for my client because they matched his financial goals and needs at the time he chose to invest in each investment. We presented multiple investments over the years to the client and educated him on the pros and cons of all of the investment options including lack of liquidity. The client is very intelligent and he did his own research on the investments and then chose to invest if he felt they matched his goals and needs. Client passed on some investments through the years that he didn't think matched his needs. I also dispute the allegation that the client, at the time of the complaint, has suffered a loss in his portfolio. At the time of filing the complaint the client has profits in his portfolio. The client and his attorney have valued the investments the client currently holds in his portfolio at no value, which is completely wrong.

The claimant alleges lack of suitability, breach of contract and lack of proper due diligence for two alternative investments purchased April 2018.

$100,100.00

$37,500.00

I feel the investments were suitable for my client because they matched her financial goals and needs at the time she invested. We presented multiple investments to the client and educated her on the pros and cons of all the investment options including lack of liquidity. The client chose the investments she felt matched her needs the best and we moved forward, accordingly. I also dispute the allegation that the client, at the time of the complaint, has suffered a loss in her portfolio. In addition, I acted only in a supervisory role with this client and I am not on the applications at all in a representative capacity so I should not have my name associated with this action.