Missouri

Between October 31, 2014, and May 16, 2018 ("Relevant Period"), while employed as an investment adviser representative and broker-dealer agent with First Allied Securities, Inc. ("FASI"), Respondent engaged in dishonest or unethical conduct, as defined under Section 409.4-412(d)(13), 15 CSR 30-51.170(1)(V) and (BB) and 15 CSR 30-51.172(1)(G) by (i) failing to provide prior written notice to and obtain prior written approval from FASI before entering into an arrangement to borrow money from a client, and (ii) failing to provide prior written notice to FASI of Outside Business Activity ("OBA") with which Respondent engaged with a client.

Order

Bar (Permanent)

From acting as an investment adviser rep and broker-dealer agent

Indefinitely

4/29/2020

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

$10,000.00

Monetary Penalty other than Fines

$2,604.25

Restitution

$46,839.00

First Allied

Discharged

RR did not comply with the firm's signature guarantee stamp requirements.

IN RESPONSE TO THE ALLEGATIONS BY FIRST ALLIED SECURITIES THAT I DID NOT FOLLOW THE PROPER PROCEDURES RELATING TO THE USE OF THE SIGNATURE GUARANTEE MEDALLION STAMP, I MAINTAIN THAT I ACTED IN GOOD FAITH AND OBSERVED THE PROCEDURES AS I UNDERSTOOD THEM. AT NO TIME DURING THE COURSE OF MY CAREER WITH FIRST ALLIED WAS MY USE OF THE STAMP CALLED INTO QUESTION UNTIL THIS INVESTIGATION. WHEN CONDUCTING SIGNATURE GUARANTEES FOR THE REPS IN MY OFFICE, I ALWAYS COMPLETE THE APPLICABLE FORM REQUIRED BY FIRST ALLIED IN ITS ENTIRETY. IF A KNOWN CLIENT DID NOT APPEAR BEFORE ME TO GUARANTEE THEIR SIGNATURE, I VALIDATED THE SIGNATURE BY COMPARING IT TO OTHER CLIENT SIGNED DOCUMENTS. IN CLOSING, I FEEL THAT I COMPLIED WITH MY RESPONSIBILITIES AS I UNDERSTOOD THEM AND HAVE NEVER BEEN TOLD DIFFERENTLY.

First Allied

Discharged

RR did not comply with the firm's signature guarantee stamp

IN RESPONSE TO THE ALLEGATIONS BY FIRST ALLIED SECURITIES THAT I DID NOT FOLLOW THE PROPER PROCEDURES RELATING TO THE USE OF THE SIGNATURE GUARANTEE MEDALLION STAMP, I MAINTAIN THAT I ACTED IN GOOD FAITH AND OBSERVED THE PROCEDURES AS I UNDERSTOOD THEM. AT NO TIME DURING THE COURSE OF MY CAREER WITH FIRST ALLIED WAS MY USE OF THE STAMP CALLED INTO QUESTION UNTIL THIS INVESTIGATION. WHEN CONDUCTING SIGNATURE GUARANTEES FOR THE REPS IN MY OFFICE, I ALWAYS COMPLETE THE APPLICABLE FORM REQUIRED BY FIRST ALLIED IN ITS ENTIRETY. IF A KNOWN CLIENT DID NOT APPEAR BEFORE ME TO GUARANTEE THEIR SIGNATURE, I VALIDATED THE SIGNATURE BY COMPARING IT TO OTHER CLIENT SIGNED DOCUMENTS. IN CLOSING, I FEEL THAT I COMPLIED WITH MY RESPONSIBILITIES AS I UNDERSTOOD THEM AND HAVE NEVER BEEN TOLD DIFFERENTLY.

CLIENTS STATE THAT ING MATERIAL PRESENTED WAS MISLEADING, AND THAT THEY DID NOT FULLY UNDERSTAND THEIR CONTRACT FROM MAY 2003 TO PRESENT.

$6,900.00

IN THE COMPLAINT THAT WAS FILED BY THE CLIENTS IT WAS MADE VERY CLEAR THEY HAD NO COMPLAINT AGAINST THEIR ADVISOR (MICHAEL E. REITHER). THEIR COMPLAINT WAS SOLELY DIRECTED AGAINST ING LIFE & ANNUITY COMPANY'S MISLEADING SALES MATERIAL.