Andrew James Aragona (CRD #1320844, Registered Representative, Deerfield Beach,Florida)

was fined $138,500 and suspended from association with any FINRA member in any capacity for one year. These sanctions were based on findings that Aragona recommended unsuitable variable annuity switches to an elderly customer.

The FINRA findings stated that Aragona failed to conduct an objective, quantitative analysis of the benefits of the recommended switches, so the customer incurred $130,000 in surrender fees, which was more than 10 percent of the value of her investment, but Aragona earned $123,500 from the switches.

The suspension is in effect from July 2, 2012, through July 1, 2013.
(FINRA Case #2010023963301)

This information was found on FINRA’s website under “Disciplinary and Other FINRA Actions, July, 2012.”

Securities Lawyer, Lars K. Soreide, of Soreide Law Group, PLLC, represents clients nationwide. Call for a free consultation on how to potentially recover your losses. To speak with an attorney call 888-760-6552, or visit our website at: http://www.securitieslawyer.com.

Andrew J Aragona Deerfield Beach FL · Andrew James Aragona Fined and Suspended by FINRA · broker failure to conduct due diligence · broker fees inflated · broker taking high fees · brokerage supervisory deficiencies · brokers recommending risky investments · elder abuse in investments · failure to supervise brokers · Financial Industry Regulatory Authority · FINRA · FINRA arbitration · Ft. Lauderdale Securities Lawyer · inadequate supervisory procedures by broker/dealers · Lars K. Soreide Soreide Law Group · risky investments · securities lawyer · stockbroker misconduct · supervisory failures · targeting elderly investors · Unsuitable investments to elderly · unsuitable variable annuities · unsuitable variable annuity switches to elderly · variable annuities · variable annuities losses · variable annuity switches

The following article was found on FINRA’s website:

Tradespot Markets Inc. (CRD #29683, Davie, Florida) and Mark Bedros Beloyan (CRD #1392748, Registered Principal, Davie, Florida)

submitted an Offer of Settlement in which the firm was censured and fined $25,000, and Beloyan was suspended from association with any FINRA member in any capacity for one month and suspended from association with any FINRA member in any principal capacity for an additional month. In light of Beloyan’s financial status, 2 Disciplinary and other FINRA Actions October 2011 FINRA did not impose any monetary sanctions upon him.

Without admitting or denying the allegations, the firm and Beloyan consented to the described sanctions and to the entry of findings that the firm, through Beloyan, sold over one billion shares of a low-priced stock that was neither registered with the Securities and Exchange Commission (SEC) nor exempt from registration. The findings stated that the firm, through Beloyan, its Chief Compliance Officer, failed to establish and maintain a supervisory system, including written supervisory procedures (WSPs), reasonably designed to ensure compliance with Section 5 of the Securities Act of 1933, the applicable rules and regulations regarding the distribution of unregistered and non-exempt securities.

These findings also stated that the firm, through Beloyan, the firm’s Anti-Money Laundering (AML) Compliance Officer (AMLCO), failed to implement or enforce the firm’s AML program by failing to identify suspicious activity, properly investigate it, and report it through Form SAR-SF, as appropriate. The findings also included that the suspicious activity consisted of deposits of billions of shares of the low-priced stock of issuers in certificate form into accounts controlled by a person with a regulatory and criminal history, liquidated those shares generally soon after their deposit, and wired of the sales proceeds out of the accounts soon after liquidation.

The article states that FINRA found that despite the suspicious nature of a company’s activity in a stock, the suspicious nature of the activity of the company’s sole owner’s non-qualified account and his regulatory and criminal history, the firm, through Beloyan, failed to conduct the necessary due diligence to determine whether they were participating in a scheme to evade registration requirements, and generally relied exclusively on the firm’s clearing firm to determine whether the subject shares of stock were registered or exempt, and did not acquire a copy of the relevant stock certificates or documents regarding the owner’s acquisition of the shares, thereby participating in the illicit distribution of more than 1 billion shares of unregistered and non-exempt stock. FINRA also found that despite the presence of risk indicators and the appearance of the activity at issue on exception reports, the firm, through Beloyan, either failed to identify or chose to ignore the suspicious activity, and thus failed to investigate and report the activity in contravention of federal laws, NASD/FINRA rules and the firm’s AML policies and procedures. In addition, FINRA determined that the firm, through Beloyan, should have detected the suspicious nature of the activity, investigated the activity and reported it through a Form SAR-SF. Moreover, the firm, through Beloyan, failed to establish and maintain a supervisory system, including WSPs, reasonably designed to ensure compliance with Section 5, and failed to establish and maintain procedures regarding the distribution of such securities in connection with its clearing firm’s acceptance of the delivery of shares of stock in certificate form and customers’ subsequent sale of the same; the firm’s WSPs did not require an inquiry into whether deposited shares of stock were registered with the SEC or exempt.

The suspension in any capacity was in effect from September 6, 2011, through October 5, 2011. The suspension in any principal capacity is in effect from September 6, 2011, through November 5, 2011. (FINRA Case #2009017590801)

Securities Attorney, Lars Soreide, of Soreide Law, PLLC, has represented clients nationwide. If you or a family member have experienced a loss through Tradespot Markets, Inc., and/or Mark Bedros Beloyan of Davie, FL, 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.

AML · AMLCO · Anti-Money Laudering compliance program · Beloyan selling unregistered stock · broker failure to conduct due diligence · broker selling unregistered stock · broker with criminal history · brokers recommending risky investments · CCO and AMLCOs not in compliance · Davie FL Tradespot Markets Inc · did not have WSPs addressing due diligence · failure to comply with AML procedures · Financial Industry Regulatory Authority · FINRA · FINRA arbitration · finra securities arbitration · finra securities arbitration lawyer · firm failed to report suspicious activity in brokerage · fort lauderdale securities fraud lawyer · fort lauderdale securities lawyer · Ft. Lauderdale Securities Lawyer · investment fraud · Lars Soreide · Mark Bedros Beloyan · Mark Beloyan · risky investments · SEC · Securities and Exchange Commission · securities arbitration · securities arbitraton lawyer · selling unregistered shares of stock · Soreide Law Group PLLC · Stock fraud lawyer · stockbroker misconduct · Tradespot Markets Inc · WSP for firm

The following appeared on FINRA’s website in the ’Disciplinary Actions.’

Brookstone Securities, Inc. (CRD #13366, Lakeland, Florida) and David William Locy (CRD #4682865, Registered Principal, Overland Park, Kansas)

the firm and Locy were censured and fined $25,000, jointly and severally. Without admitting or denying the findings, the firm and Locy consented to the described sanctions and to the entry of findings that the firm, acting through Locy, did not have WSPs addressing due diligence requirements for third-party placements.

 These findings stated that the firm, acting through Locy, failed to conduct an adequate due diligence of a third-party private placement offering before Locy approved the offering of shares to customers. The findings also stated that Locy’s due diligence efforts did not include any investigation into an equity fund, despite acknowledging that he knew very little about it or the third-party placement and could not get any solid information about the fund, including pending litigation or financial statements.

These findings also included that Locy knew nothing about the fund that was not contained in a PPM the issuer prepared, but accepted that the firm representatives forming the offering had conducted due diligence and relied on their opinion of the fund.

Additionally, FINRA found that Locy acknowledged  the representatives had limited, if any, experience forming a private placement. FINRA also found that firm representatives sold or participated in sales of shares to customers without notifying Locy or anyone else at the firm, which caused those sales to not be recorded on the firm’s books and records.      (FINRA Case #20090198373)

Brookstone Securities, Inc. (CRD # 13366, Lakeland, Florida), Richard Joseph Buswell (CRD #4770105, Registered Representative, Lafayette, Louisiana) and Herbert Steven Fouke (CRD #5523938, Registered Representative, Lafayette, Louisiana)

 respondents in a FINRA complaint alleging that the firm, acting through Buswell andFouke, made misrepresentations and/or omissions of material fact in connection with the sale of unsecured bridge notes and warrants. The complaint alleges that Buswell and Fouke, acting on the firm’s behalf, told purchasers of the bridge notes that they were guaranteed without any reasonable basis given the description of the placement agent’s limited role in the Private Placement Memorandum (PPM) and disclosed no risks regarding the financing or financial health of the placement agent or the issuer of the bridge notes and warrants.

Additionally, the complaint alleges that Buswell and Fouke provided unwarranted price predictions to customers regarding the future price of common stock for which warrants would be exchangeable. The complaint further alleges that Buswell and Fouke, acting on the firm’s behalf, guaranteed the payment at maturity of promissory notes although the PPM made clear that the placement agent had no commitment to provide financing for the private placement or a later public offering.

The complaint alleges that Buswell and Fouke, acting on the firm’s behalf, recklessly or knowingly failed to disclose the risk that the financing would not occur and recklessly or knowingly failed to disclose the other risks outlined in the PPM. The complaint alleges that Buswell and Fouke, acting on the firm’s behalf, guaranteed to customers that they would receive back their principal investments plus returns, failed to inform investors of any risks associated with the investments and did not discuss the risks outlined in the PPM that could result in investors losing their entire investment. The complaint also alleges that the firm, acting through Buswell, made misrepresentations and/or omissions of material fact in connection with the sale of the private placement of firm units consisting of Class B common stock and warrants to purchase Class A common stock to customers; the PPM for the firm self-offering stated that the investment was speculative, involving a high degree of risk and was only suitable for persons who could risk losing their entire investment, and the PPM also stated that the investment was illiquid, contrary to Buswell’s representations.

Also, the complaint further alleges that Buswell represented to customers that he would invest their funds in another private placement, and in direct contradiction, invested the funds in the firm’s private placement. In addition, the complaint alleges that the firm, acting through Buswell and Fouke, recommended and effected the sale of securities without having a reasonable basis to believe that the transactions were suitable given the customers’ financial circumstances and conditions; Buswell recommended a trading strategy that relied upon frequent trading, use of margin and concentration of the accounts in a small number of financial stocks. The complaint alleges that Buswell exercised discretion in customers’ accounts without the customers’ prior written authorization or the firm’s acceptance of the accounts as discretionary. The complaint also alleges that the firm, acting through its chief executive officer (CEO) and its president, failed to reasonably supervise Buswell, and failed to follow up on red flags that should have alerted them to the need to investigate Buswell’s sales practices and determine whether trading restrictions, heightened supervision or discipline were warranted. The complaint further alleges that the firm, acting through its CEO, president and chief compliance officer, failed to establish, maintain and enforce supervisory procedures reasonably designed to prevent violations of NASD Rule 2310 regarding suitability; the firm’s procedures were also inadequate to prevent and detect unsuitable recommendations resulting from excessive trading, excessive use of margin and over-concentration. The complaint alleges that the firm’s new account application process was flawed so that a reviewing principal was unable to obtain an accurate picture of customers’ financial status, investment objectives and investment history when reviewing a transaction for suitability. The complaint also alleges that the firm’s procedures failed to identify specific reports that its compliance department was to review and provided no guidance on the actions or analysis that should occur in response to the reports.(FINRA Case #2009017275301)

This information appeared on FINRA’s website in the ‘Disciplinary Actions, 2011.’

Securities Attorney, Lars Soreide, of Soreide Law, PLLC, has represented clients nationwide. If you or a family member have experienced a loss through Brookstone Securities, Inc., and/or David W. Locy, Richard J. Buswell, Herbert S. Fouke, 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.

bridge notes scam · broker failure to conduct due diligence · brokers recommending risky investments · Brookstone Securities · brookstone securities inc · Brookstone Securities Lakeland Florida · Class A common stock · Class B common stock · David Locy · David William Locy · did not have WSPs addressing due diligence · due diligence for private offerings · due diligence requirements for third-party placements · elder abuse in investments · failure to do due diligence by brokers · Financial Industry Regulatory Authority · FINRA · finra securities arbitration · finra securities arbitration lawyer · fort lauderdale securities fraud lawyer · Ft. Lauderdale Securities Lawyer · Herbert Fouke · Herbert Steven Fouke · high risk investments · inadequate due diligence by brokers · Lars Soreide · Limited experience forming a private placement · NASD Rule 2310 · no equity fund investigation · PPM · private placements · Richard Buswell · Richard Joseph Buswell · risky investments · securities arbitraton lawyer · securities fraud lawyer · securities lawyer · Soreide Law Group PLLC · Stock fraud lawyer · targeting elderly investors · third party placemnts · third-party private placement offerings · unsecured bridge notes and warrants · unwarranted price predictions · updating firms WSPs