Securities Lawyer Blog | Victim of Fraud?

Archive for December 2011

Dec/11

30

Did you Invest with Jason May?

Comments off · Posted by Securities Lawyer in FINRA

Former Ameriprise broker, Jason May (CRD# 4255401), in Delray Beach and Boynton Beach, Florida, has been barred for life by FINRA for failing to respond to FINRA requests for information after he was suspended for 60 days.
 
Our investigation has uncovered that Mr. May may have encouraged his clients to take out loans through a friend of his at Wachovia. It has been alleged that Mr. May then invested the proceeds in options trading at Options Express. Ameriprise may be liable for the losses sustained by May’s clients at Options Express.
 
In addition, May failed to sit for the Series 63 or 66 state licensing exams. As a result, May was not properly registered in the state of Florida during his tenure with  Ameriprise. Accordingly, Ameriprise may be held liable for any losses sustained, or fees, commissions, or costs paid by those clients to Ameriprise.  It is believed that Ameriprise failed to disclose to May’s clients that he wasn’t properly registered. Instead Ameriprise advised clients that May had changed positions with the firm, which happened to be a non-registered paraplanner.
 
 After May continued acting in a registered capacity, our investigation has uncovered that Ameriprise failed to fully report the reasons for May’s departure from the firm on May’s CRD. Due to May’s improper registration, May’s clients at Ameriprise may be entitled to recovery for losses sustained. Furthermore, clients suffering losses through May at Options Express may also be entitled to recovery from Ameriprise for May’s selling away
 
If you had dealings with former Ameriprise broker Jason May please contact Soreide Law Group for a free consultation at (888) 760-6552 or locally at (954) 760-6552 or visit us on the web at http://www.securitieslawyer.com

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Dec/11

23

Dawson James Securities, Inc., of Boca Raton, and Two Florida Reps Fined and Censured by FINRA

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Dawson James Securities, Inc. (CRD® #130645, Boca Raton, Florida), Albert
James Poliak (CRD #1270681, Registered Principal, Parkland, Florida), and
Douglas Fulton Kaiser (CRD #1674570, Registered Principal, Deerfield Beach,
Florida)
 
submitted Offers of Settlement in which the firm was censured and fined $90,000. Poliak, Dawson’s CEO, and Kaiser, who acted at times as both the firm’s head of trading and the Financial and Operations Principal (FINOP), were each fined $30,000 and suspended from association with any FINRA®-regulated broker-dealer in any capacity for one year.
 
Without admitting or denying the allegations, Dawson, Poliak and Kaiser consented to these sanctions and to the entry of findings that the firm entered into a de facto commission recapture agreement with a firm customer without meeting the minimum required net capital of $250,000 and without filing an application for amendment of the firm’s FINRA membership agreement.
 
These findings stated that the firm and a customer entered into a consulting agreement whereby the customer was to provide research and advisory services. However, the firm did not request, nor did the customer provide, research reports or advisory services or any of the other services set forth in the consulting agreement.
 
Additionally, the firm paid the customer a total of $1,215,000, which exceeded by $885,000 the payments due to the customer per the contractual requirements under the consulting agreement. The payments exceeded the contractual requirements of the consulting agreement because the agreement was a de facto commission recapture arrangement through which the customer was paid larger amounts based upon the level of security transactions the customer was executing in its brokerage account at the firm.
 
These findings also stated that Poliak was responsible for the creation of the consulting agreement and approved each wire transfer payment to the customer, including the payments that were in excess of amounts due to the customer under the consulting agreement.
 
These findings also included that Kaiser was responsible for calculating the payments owed to the customer and that he pulled research concerning the customer’s trades in an effort to document the consulting agreement, but the firm was unable to document its use of the purported research or other financial benefit arising from the consulting agreement.
 
Poliak and Kaiser acted unethically in that they facilitated the improper commission recapture arrangement between the firm and customer, and caused the firm to fail to comply with the requirement of NASD® Rule 1017.
 
Also, FINRA found that the firm, acting through Poliak and Kaiser, violated the
Customer Protection Rule in several ways. First, in connection with the commission recapture agreement described above, the firm held, or was in control of, customer funds without establishing a special reserve bank account for the exclusive benefit of the customer in violation of Securities Exchange Act Rule 15c3-3, By holding customer funds
and failing to forward the funds to its clearing firm, the firm became a broker or dealer that receives and holds funds for customers, which required it to increase its net capital
and establish a reserve bank account for customer protection. Second, after a commission recapture agreement was ultimately established for the customer by the firm’s clearing firm, the firm deposited into its own checking account a check from the clearing firm which included at least $136,700 in commission rebates due to the customer. Rather than record a liability to the customer, the firm made a journal entry to reduce the commission receivable. The firm’s receipt of customer funds increased its minimum net capital to $250,000, a level that the firm did not meet, Third, the firm held and segregated security positions in its proprietary account for the benefit of two customers in order to satisfy the obligation of promissory notes and a confidential private placement memorandum (PPM). Fourth, the firm acted in the capacity of a noteholder’s agent to facilitate the repayment to firm customers of $2,715,000 of principal plus interest on defaulted notes and warrants issued by an unaffiliated issuer. By doing so, the firm acted in a carrying, transferring and safekeeping capacity for customers, which required the firm to maintain a minimum net capital of at least $250,000. The firm’s net capital was below that required minimum, and as a result the Financial and Operational Combined Uniform Single (FOCUSTM) reports it filed, and its books and records, were inaccurate. The firm also failed to timely file Securities and Exchange Commission (SEC) Rule 17a-11 notices when notified by its designated examining authority that the broker-dealer’s net capital was, or had been, below its
minimum requirement.
 
When acting in the capacity as the firm’s FINOP, Kaiser, was responsible for supervision
and/or performance of the firm’s compliance under all financial responsibility rules
promulgated pursuant to provisions of the Securities Exchange Act of 1934. Kaiser failed
to adequately perform his FINOP responsibilities in that he failed to take adequate steps to ensure the accuracy of the firm’s net capital calculations. In addition, as Poliak participated in the firm’s holding of customer funds in violation of Rule 15c3-3, Poliak caused the firm’s net capital and books and records violations.
 
Also, FINRA determined that the firm’s compensation committee did not document the basis upon which a research analyst’s compensation was established, thus failing to establish a written record of whether specific factors required by NASD Rule 2711 were properly considered, and whether research analyst compensation was tied to any investment banking activities. Moreover, FINRA found that a senior officer at the firm inaccurately represented in required attestations submitted to FINRA that the compensation committee documented the basis upon which each research analyst’s
compensation was established. The senior officer should have known that each attestation submitted contained false information. Furthermore, FINRA found that the firm sold securities for customer accounts that were not registered pursuant to Section 5 of the Securities Act of 1933, nor exempt from registration; the sales constituted an unregistered distribution by the firm.
 
Kaiser’s and Poliak’s suspensions are in effect from November 7, 2011, through November 6, 2012. (FINRA Case #2009016158501)
 
This information is from FINRA’s website’s ‘Disciplinary Actions,’ December, 2011.
 
Securities Attorney, Lars Soreide, of Soreide Law Group, PLLC, has represented clients nationwide. If you or a family member have experienced losses through Albert James Poliak, Douglas Fulton Kaiser, or Dawson James Securities, Inc., call a Securities Arbitration Lawyer for a free consultation on how to potentially recover your losses. To speak with an attorney, call 888-760-6552, or visit www.securitieslawyer.com.

Soreide Law Group, PLLC., representing investors nationwide before FINRA the Financial Industry Regulatory Authority.

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Dec/11

23

Elevation LLC, Fined and Censured by FINRA

Comments off · Posted by Securities Lawyer in FINRA

Elevation, LLC (CRD #140341, Charlotte, North Carolina)
 
submitted a Letter of Acceptance, Waiver and Consent in which the firm was censured and fined $10,000.
 
Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings that it commenced an options business, engaged in options transactions and designated an individual as its Registered Options Principal (ROP) until his resignation from the firm.
 
These findings stated that the firm did not notify FINRA of his resignation but instead continued to engage in options business without registering a new ROP.
 
Also, the findings stated that the firm failed to establish, maintain and enforce an adequate supervisory system for its options activities, including written procedures, reasonably designed to achieve compliance with application securities regulations, and to supervise options transactions in which it engaged.
 
These findings also included that the firm failed to comply with multiple requirements of FINRA Rule 2360, the options rule, by failing to comply with its registration and customer agreement requirements.
 
(FINRA Case #2010021236201)
 
This information is from FINRA’s website’s ‘Disciplinary Actions,’ December, 2011.
 
Securities Attorney, Lars Soreide, of Soreide Law Group, PLLC, has represented clients nationwide. If you or a family member have experienced losses through Elevation, LLC, call a Securities Arbitration Lawyer for a free consultation on how to potentially recover your losses. To speak with an attorney, call 888-760-6552, or visit www.securitieslawyer.com.

Soreide Law Group, PLLC., representing investors nationwide before FINRA the Financial Industry Regulatory Authority.

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Dec/11

20

Boca Raton Rep Barred by FINRA

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Joseph Alphonse Vitale (CRD #5223467, Registered Representative, Boca Raton, Florida)
 
has been barred from association with any FINRA member in any capacity. The sanction was based on findings that Vitale failed to respond to FINRA requests for information.
 
(FINRA Case #2009017585202)
 
This information is from FINRA’s website’s Disciplinary Actions, December, 2011.
 
Securities Attorney, Lars Soreide, of Soreide Law Group, PLLC, has represented clients nationwide. If you or a family member have experienced losses through Joseph Alphonse Vitale, call a Securities Arbitration Lawyer for a free consultation on how to potentially recover your losses. To speak with an attorney, call 888-760-6552, or visit www.securitieslawyer.com.

Soreide Law Group, PLLC., representing investors nationwide before FINRA the Financial Industry Regulatory Authority.

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Dec/11

20

Evan Taber, Plantation, FL, Barred by FINRA for Misappropriation of Funds

Comments off · Posted by Securities Lawyer in FINRA

Evan Taber (CRD #1892751, Registered Representative, Plantation, Florida)
 
was barred from association with any FINRA member in any capacity.
 
This sanction was based on findings that Taber intentionally converted or misappropriated customer funds. These findings stated that Taber discussed with a customer an investment that would yield a 15 percent rate of return and the customer gave Taber a check for $30,000 payable to the investment; Taber deposited the customer’s check into the investment checking account.
 
FINRA’s findings also stated that the customer repeatedly called Taber to determine the status of his investment, and each time Taber reassured the customer that his funds had been invested; Taber failed to inform the customer that the investment checking account was actually Taber’s personal bank account.
 
These findings also included that Taber did not make any investment with the customer’s funds; instead, Taber used the customer’s funds for numerous business and personal expenses. FINRA found that Taber ultimately refunded the customer’s funds, but not until FINRA began its investigation into the customer’s complaint.
 
 (FINRA Case #2010021196801)
 
This information is from FINRA’s website’s Disciplinary Actions, December, 2011.
 
Securities Attorney, Lars Soreide, of Soreide Law Group, PLLC, has represented clients nationwide. If you or a family member have experienced losses through Evan Taber, call a Securities Arbitration Lawyer for a free consultation on how to potentially recover your losses. To speak with an attorney, call 888-760-6552, or visit www.securitieslawyer.com.

Soreide Law Group, PLLC., representing investors nationwide before FINRA the Financial Industry Regulatory Authority.

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Dec/11

19

Jeffrey Rachlin Fined and Sanctioned by FINRA

Comments off · Posted by Securities Lawyer in FINRA

Jeffrey Rachlin (CRD #823547, Registered Principal, Pleasantville, New York)
 
has submitted a Letter of Acceptance, Waiver and Consent in which he was fined $10,000, suspended from association with any FINRA member in any capacity for 30 business days, and suspended from association with any FINRA member in any principal capacity for 18 months. The fine must be paid either immediately upon Rachlin’s reassociation with a FINRA member firm following his all-capacity suspension, or prior to the filing of any application or request for relief from any statutory disqualification, whichever is earlier.
 
FIRNA reports that without admitting or denying the findings, Rachlin consented to the described sanctions and to the entry of findings that his member firm, acting through Rachlin and another firm principal, negligently omitted material facts in connection with its sales of promissory notes to investors.
 
These findings stated that the notes were issued by an entity which was controlled by a real estate developer. The firm, acting through Rachlin and another firm principal, negligently failed to disclose to investors that the entity had been experiencing cash flow problems and that the entity and other companies affiliated with the real estate developer had failed to make required interest payments to investors. The findings also stated that the firm, acting through Rachlin and another firm principal, negligently failed to disclose that it was unlikely that the entity’s affiliated company would be able to make its scheduled principal payments totaling $10 million that were due to its note holders.
 
 These findings also included that Rachlin helped prepare a document called “Investor Letter” for a company; the letter was later distributed by his firm. The Investor Letter constituted a research report, but it failed to disclose a firm representative’s ownership interest in the company and his receipt of compensation from the company.
 
Also, FINRA found that Rachlin helped prepare presentations regarding the company, which the firm’s registered representatives used to solicit potential investors at seminars. The presentations contained statements and projections that were without basis and were false, exaggerated, unwarranted and/or misleading, and failed to provide a balanced presentation by omitting material information regarding the significant risks associated with an investment in the company.
 
This suspension in any capacity is in effect from November 7, 2011, through December 19, 2011. The suspension in any principal capacity is in effect from November 7, 2011, through May 6, 2013. (FINRA Case #2010021058403)
 
This article is from FINRA’s website under ‘Disciplinary and Other FINRA Actions December 2011.’
 
Securities Attorney, Lars Soreide, of Soreide Law Group, PLLC, has represented clients nationwide. If you or a family member have experienced losses through Jeffrey Rachlin, call a Securities Arbitration Lawyer for a free consultation on how to potentially recover your losses. To speak with an attorney, call 888-760-6552, or visit www.securitieslawyer.com.

Soreide Law Group, PLLC., representing investors nationwide before FINRA the Financial Industry Regulatory Authority.

 

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Dec/11

19

Alan S. Pattee, Lake Worth, FL, Rep Barred from FINRA

Comments off · Posted by Securities Lawyer in FINRA

Alan Stuart Pattee (CRD #3002976, Registered Representative, Lake Worth, Florida)
 
has submitted a Letter of Acceptance, Waiver and Consent in which was barred from
association with any FINRA member in any capacity. Without admitting or denying the findings, Pattee consented to the described sanction and to the entry of findings that
he forged homeowner signatures on uniform mitigation verification inspection forms
(UMVI forms) in connection with inspections performed by a qualified inspector regarding construction information; the form is submitted to the homeowner’s insurance company in connection with insurance pricing.
 
 These findings stated that Pattee forged the signatures to accommodate his clients, who were either not at home at the time of the inspection or were his longtime clients. The findings also stated that Pattee acted as an officer for a company formed to conduct inspections to determine homeowner policy premiums, for compensation, without providing prompt written notice to his member firm for this outside business activity.
 
FINRA’s findings also included that Pattee completed securities annual compliance online certifications for his firm representing that he had complied with the requirements of NASD Rule 3030 and for the certifications, certified that no changes were needed to his Form U4 or that he had requested appropriate changes to the Form U4 regarding outside business activities.
 
(FINRA Case #2010023232101)
 
This information is from FINRA’s website’s Disciplinary Actions, December, 2011.
 
Securities Attorney, Lars Soreide, of Soreide Law Group, PLLC, has represented clients nationwide. If you or a family member have experienced losses through Alan Stuart Pattee, call a Securities Arbitration Lawyer for a free consultation on how to potentially recover your losses. To speak with an attorney, call 888-760-6552, or visit www.securitieslawyer.com.

Soreide Law Group, PLLC., representing investors nationwide before FINRA the Financial Industry Regulatory Authority.

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Dec/11

19

Boca Raton Rep, Alan Goddard, Jr., Fined and Suspended by FINRA

Comments off · Posted by Securities Lawyer in FINRA

Alan David Goddard Jr. (CRD #3019681, Registered Representative, Boca Raton, Florida)
 
has submitted a Letter of Acceptance, Waiver and Consent in which he was fined $10,000 and suspended from association with any FINRA member in any capacity for 45 days. This fine must be paid either immediately upon Goddard’s reassociation with a FINRA member firm following his suspension, or prior to the filing of any application or request for relief from any statutory disqualification, whichever is earlier.
 
Without admitting or denying the findings, Goddard consented to the described sanctions and to the entry of findings that he was actively engaged in a member firm’s investment banking and securities business as a principal without proper registration.
 
These findings stated that Goddard signed selling agreements and consulting agreements with issuers on the firm’s behalf as an officer of the firm and worked closely with the firm’s outside counsel to establish the terms of selling agreements and private placement offerings that the firm conducted. Unbeknownst to Goddard, the firm’s CCO amended the firm’s Application for Broker-Dealer Registration (Form BD) to list Goddard as the firm’s CEO.
 
FINRA’s findings also stated that during Goddard’s entire association with the firm, he was only registered as a general securities representative; Goddard took the Series 24 examination but failed. Goddard erroneously believed that he could function in the capacities set forth above without a principal’s license.
 
This suspension was in effect from October 17, 2011, through November 30, 2011. (FINRA Case #2009016157802)
 
This information is from FINRA’s website’s Disciplinary Actions, December, 2011.
 
Securities Attorney, Lars Soreide, of Soreide Law Group, PLLC, has represented clients nationwide. If you or a family member have experienced losses through Alan David Goddard, Jr., call a Securities Arbitration Lawyer for a free consultation on how to potentially recover your losses. To speak with an attorney, call 888-760-6552, or visit www.securitieslawyer.com.

Soreide Law Group, PLLC., representing investors nationwide before FINRA the Financial Industry Regulatory Authority.

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Dec/11

19

Timothy McGinn and David Smith Barred by FINRA

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Timothy Michael McGinn (CRD #813935, Registered Principal, Schenectady, New York) and David Lee Smith (CRD #427284, Registered Principal, Saratoga Springs, New York)

were barred from association with any FINRA member in any capacity. The sanctions were based on findings that Smith misused investor funds when he sold approximately $89 million in income notes issued by four limited liability companies he controlled.

David Smith told the investors that the Income Note LLCs would place their funds in a broad array of public and private investments. Contrary to Smith’s representations, he diverted most of the invested funds for the benefit of business entities that he and McGinn owned or in which they had a financial interest. Smith also loaned approximately $590,000 of funds directly to himself. The findings also stated that Smith made misrepresentations and omissions of material facts relating to the Income Note LLCs when he recommended to investors that they participate in the private offerings and purchase the income notes.

Additionly, to falsely representing that the Income Note LLCs would place their funds in private and public investments, Smith stated that the member firm would charge an annual 2 percent commission or fee. In actuality, the proceeds of the investments were diverted to entities McGinn and Smith owned, which were illiquid and in poor financial condition with little or no revenues, and the firm charged recurring annual commissions or fees amounting to approximately 8 percent of the investors’ purchases. Smith failed to inform investors that the Income Note LLCs would invest in, and make loans to, entities in which he and McGinn maintained a financial interest, and that the majority of the funds would be invested in illiquid, non-public companies.

These findings also included that Smith directed the sales efforts by which customers purchased the Income Note LLCs. The notes were not registered with the SEC and were not eligible for exemption from registration, but the offerings falsely claimed to be exempt from the registration requirement pursuant to Rule 506 of the Securities Act of 1933, Regulation D.

Also, FINRA found that Smith sent letters to income note investors containing material misrepresentations and omissions concerning their investments. One letter informed certain Income Note LLCs holders that their annual interest rates of return would bereduced because of market conditions, and Smith falsely represented that the firm would suspend further collection of fees from the Income Note LLCs but it continued to collect them, totaling approximately $6.7 million. Another letter informed all Income Note LLC holders that they would be unable to redeem notes on a particular day because of conditions in financial credit markets and the resultant liquidity crises. Smith also falsely represented that the firm would forfeit all annual fees and commissions in order to improve the liquidity of the Income Note LLCs, but it continued to charge fees and commissions.

Present in both letters, Smith failed to disclose to the note holders that the poor financial condition of the Income Note LLCs was caused in part by his decision to lend or invest most of the investors’ funds in illiquid entities that he and McGinn owned and controlled, had few or no revenues, and were in financial distress. FINRA also found that the firm, through Smith, failed to establish and maintain a supervisory system, and failed to establish, maintain and enforce WSPs reasonably designed to achieve compliance with the applicable FINRA rules and securities laws related to suitability, disclosure and verification of investor accreditation status.

FINRA reports that for approximately five years, the firm’s principal source of revenues was from private placements, including the Income Note LLCs. The subscription contracts potential investors submitted in income note offerings were inadequate because they did not contain information about the investors’ liquid net worth, but the firm relied on them to review and approve individual investments; many investor documents were incomplete, and many were altered after they were submitted by the investors to make it appear that the investors had a higher net worth and qualified as accredited investors.

The firm did not have, and Smith did not implement, procedures for reviewing customer documents reasonably designed to allow the firm to identify any potential alterations and to take appropriate action, and did not have a procedure for spot-checking customer documents and contacting customers directly to ascertain if the documents were accurate.

Despite the fact that the PPM for the income notes and subscription agreements provided that only accredited investors would be eligible to invest, Smith approved and accepted investments from approximately 250 non-accredited investors.

FINRA found that McGinn and Smith provided false documents to FINRA in response to requests for information relating to loans from certain business entities they controlled.

McGinn and Smith submitted copies of promissory notes relating to the loans, dated to appear that they had been previously signed; each note contained a certification attesting that it had been executed and delivered on the date specified. The certifications were false, as McGinn, Smith and a registered representative actually prepared, dated and signed the notes after the FINRA request for documents.

 (FINRA Case #2009017984501)

This article was obtained from FINRA’s website’s Disciplinary Actions of December 2011.

 

Securities Attorney, Lars Soreide, of Soreide Law Group, PLLC, has represented clients nationwide. If you or a family member have experienced losses through Timothy Michael McGinn, David Lee Smith or Income Note LLC, call a Securities Arbitration Lawyer for a free consultation on how to potentially recover your losses. To speak with an attorney, call 888-760-6552, or visit www.securitieslawyer.com.

Soreide Law Group, PLLC., representing investors nationwide before FINRA the Financial Industry Regulatory Authority.

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Dec/11

8

DeWaay Financial Network Facing Bankruptcy Because of DBSI Lawsuits

Comments off · Posted by Securities Lawyer in FINRA

In an InvestmentNews.com article by Bruce Kelly, he writes that failed private placements issued by Medical Capital Holdings Inc. and Provident Royalties LLC have forced dozens of broker-dealers to close, be sold or seek bankruptcy protection.

Failed real estate tenant-in-common syndicator DBSI Inc. is threatening to have the same result, with DeWaay Financial Network LLC claiming in federal court last month that bankruptcy looms, due to lawsuits by clients who bought DBSI securities.

Kelly writes that DeWaay Financial Network asked a federal judge in Delaware in October for a temporary injunction to halt eight arbitration claims that investors have filed with the Financial Industry Regulatory Authority Inc. stemming from DBSI losses.

DeWaay Financial Network “lacks sufficient funds to satisfy the claims in eight arbitration claims pending against it — let alone the potential claims of 304 other customers that have not yet brought suit. The threat posed by these mounting costs and the attendant potential for liability hangs over defendant’s limited funds like the Sword of Damocles,” according to the firm’s memorandum, which was filed in U.S. District Court in Delaware on Oct. 19.

“Absent injunctive relief, that sword’s descent is imminent and in all likelihood would force defendant to declare bankruptcy,” according to the memo.

DeWaay’s request for an injunction is part of its strategy to create a settlement with investors, president Matt Stahr said.

“We still feel like we’re in the right,” as the firm did its due diligence on the DBSI products, but the costs of defending the firm in individual arbitration claims are prohibitive, he said. The firm has made substantial progress toward reaching a settlement but hasn’t had a hearing yet regarding its request for an injunction, Mr. Stahr said.

DBSI raised $1 billion from investors by selling real estate deals through independent broker-dealers. The real estate firm declared bankruptcy in 2008, writes Kelly.

The InvestmentNew.com article said that according to court filings, the eight DeWaay Financial Network clients suing the firm in Finra arbitration bought $2.9 million in DBSI securities. DeWaay Financial Network so far has spent $46,000 defending those claims and expects to spend another $1.1 million in defense costs. Beyond those investors, DeWaay Financial Network sold DBSI securities to an additional 304 clients, and the firm’s total exposure exceeds $24 million.

Securities Attorney, Lars Soreide, of Soreide Law, PLLC, has represented clients nationwide. If you or a family member have experienced losses with DeWaay Financial Network LLC, and/or were sold DBSI TICs, through DeWaay or other broker/dealers, call a Securities Arbitration Lawyer for a free consultation on how to potentially recover your losses. To speak with an attorney, call 888-760-6552, or visit www.securitieslawyer.com.

Soreide Law Group, PLLC., representing investors nationwide before FINRA the Financial Industry Regulatory Authority.

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