FINRA

Respondent Towers failed to respond to FINRA request for information. On September 17, 2015, pursuant to FINRA Rule 9552, FINRA issued a Notice of Suspension to Respondent for his failure to provide information, which was requested in accordance with FINRA Rule 8210. The Notice informed Respondent that: (i) he would be suspended effective October 13, 2015, if he did not take corrective action by that date; (ii) he could request a hearing by October 13, 2015, pursuant to Rule 9552(e), which would stay the effective date of the suspension; and (iii) he would be automatically barred, pursuant to Rule 9552(h), effective December 21, 2015, if he did not request termination of his suspension.

letter

Bar (Permanent)

All Capacities

Indefinite

12/21/2015

On October 7, 2015, Respondent timely filed a request for a hearing pursuant to FINRA Rule 9552(e), staying the imposition of the suspension. A hearing is scheduled in this matter for December 2-3, 2015. On November 27, 2015, Respondent filed a Notice withdrawing his request for a hearing. Accordingly, Respondent's request for a hearing was dismissed, and FINRA's September 17, 2015, Notice of Suspension constitutes FINRA's final action in this proceeding. As set forth in the Notice of Suspension, and with the issuance of the Order, Respondent was immediately suspended from associating with any member firm in any capacity, pursuant to Rule 9552(e), and he is therefore barred from associating with any member firm in any capacity, effective December 21, 2015, pursuant to Rule 9552(h). Thus; pursuant to FINRA Rule 9552(h) and in accordance with FINRA's Notice of Suspension and Suspension from Association letters dated September 17, 2015 and October 13, 2015, respectively, on December 21, 2015, Towers is barred from association with any FINRA member in any capacity. Respondent failed to request termination of his suspension within three months of the date of the Notice of Suspension; therefore, he is automatically barred from association with any FINRA member in any capacity. Associated case number is Expedited Proceeding No. FPI150010

FINRA

FINRA RULE 2010 AND NASD RULES 2110, 2210(D) AND 2310: TOWERS RECOMMENDED THAT A MARRIED COUPLE INVEST IN A HIGH RISK PRIVATE PLACEMENTS AND REAL ESTATE INVESTMENT TRUSTS (REITS), TOTALING APPROXIMATELY $6,259,400 AND REPRESENTING APPROXIMATELY 72% OF THEIR INVESTMENTS PURCHASED. THE PRIVATE PLACEMENTS AND REITS RECOMMENDED BY TOWERS WERE ALL DESCRIBED IN THE OFFERING DOCUMENTS AS HIGH RISK INVESTMENTS. THE COUPLE HAD STATED A MODERATE RISK TOLERANCE ON THEIR NEW ACCOUNT FORMS AND SPECIFIED THAT NO MORE THAN 10% OF THEIR ACCOUNT BE INVESTED IN HIGH RISK PRODUCTS AND EXPRESSED TO TOWERS THAT THEY WERE UNCOMFORTABLE WITH THE VOLATILITY OF THE STOCK MARKET. THE RECOMMENDATIONS THAT THE COUPLE INVEST IN PRIVATE PLACEMENTS AND REITS WAS NOT SUITABLE. TOWERS PROVIDED CONSOLIDATED STATEMENTS TO THE COUPLE FOR THEIR ACCOUNTS WITH HIS FIRM AND USED THE CONSOLIDATED STATEMENTS TO REPORT TO THE COUPLE ON THE VALUE OF ALL OF THEIR INVESTMENTS, INCLUDING PRIVATE PLACEMENTS AND REITS. TOWERS MANUALLY ENTERED VALUES FOR THE PRIVATE PLACEMENTS AND REITS. DESPITE THE INSTRUCTIONS PROVIDED BY HIS FIRM, TOWERS VALUED THE INVESTMENTS HIMSELF, USING PRICES THAT HAD NO CORRELATION TO PRICES PUBLISHED BY THE FIRM. AND DESPITE KNOWING THAT THE VALUES OF THE INVESTMENTS HAD DECLINED, TOWERS LISTED THE COUPLE'S ORIGINAL COST BASIS AS THE VALUE OF THE INVESTMENTS, RATHER THAN THE ACTUAL CURRENT VALUE SPECIFIED BY THE FIRM.

Acceptance, Waiver & Consent(AWC)

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

$25,000.00

Suspension

ANY CAPACITY

THREE MONTHS

1/21/2014

4/20/2014

WITHOUT ADMITTING OR DENYING THE FINDINGS, TOWERS CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE HE IS FINED $25,000 AND SUSPENDED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY FOR THREE MONTHS. THE SUSPENSION IS IN EFFECT FROM JANUARY 21, 2014 THROUGH APRIL 20, 2014.