The Financial Industry Regulatory Authority (“FINRA”) announced that it issued Titan Securities’ sole owner, CEO and president, Brad Brooks (CRD#:1584633, Addison, Texas) a suspension and $50,000 fine. Apparently, in an Extended Hearing Panel Decision, FINRA found that Brooks violated FINRA and NASD Rules because Brooks failed to establish and enforce a supervisory system to preserve e-mails relating to the firm’s securities business. Not only that, but FINRA stated that Brooks unlawfully released clients’ funds held in escrow prior to the firm raising the minimum offering amount for Evolution II. Here’s more on the matter:
First of all, the Decision said that six Titan securities representatives used their private e-mails to do securities business. The firm’s failure to retain and supervise those communication caused the firm to violate NASD Rules 3010 and 3110, FINRA Rules 4511 and 2010, and Section 17(a) of the Exchange Act. Namely, NASD Rules 3010 and 3110 required that Titan retain correspondence for at least three years. Additionally, NASD Rule 3010 required that a Titan registered principal review all of the firm’s securities transactions and the representatives’ correspondence pertaining to securities business. Evidently, Brad Brooks admitted that his brokers used their personal e-mails to conduct securities business.
The findings show that Titan was managing broker-dealer for limited partnership units that Evolution II issued. Supposedly, Evolution II’s agenda was to buy another limited partnership’s units. That other limited partnership was set up to acquire a Stone Mountain, Georgia business center. Apparently, Brooks was majority owner of Evolution II GP, LLC, the general partner of Evolution II.
FINRA says that Brad Brooks tried to raise at least $1,000,0000. Indeed, the Evolution II PPM stated that the offering, made on a contingency basis, was designed to generate between $1,000,000 and $3,000,000. Apparently, Evolution II GP, LLC was supposed to hold investors’ funds until Evolution II sold the minimum amount. However, if Evolution II GP, LLC did not raise the minimum amount, the partnership would end the offering. Supposedly, Evolution II only raised $300,000 by the time Titan broke escrow. That is, it released the investors’ funds to Evolution II GP, LLC without authorization. Because of this, the Hearing Panel said Titan violated Section 15(C) of the Exchange Act and Rule 15c2-4.
At least two clients brought claims about Brooks’ activities since October 27, 2017.
A client of Titan Securities brought FINRA Arbitration #: 18-02577 on July 24, 2018. Mainly, the client alleged that Brad Brooks did not supervise direct investments which the firm sold the client. Supposedly, the firm sold limited partnership interests that caused the clients to experience unreasonable losses. Because of this, on October 10, 2018, Titan Securities paid the client $9,850 to settle the matter.
A second Titan Securities client brought FINRA Arbitration #: 17-02747 on October 27, 2017. According to the client, Brad Brooks failed to supervise the representative who sold or purchased OTC Equities for the client’s account. Allegedly, because of this alleged lack of supervision, the client sustained $300,000 in losses. Therefore, the client sued to recover the losses in this pending matter.
Have you experienced losses because of Titan Securities and its CEO, Brad Brooks? If so, contact Soreide Law Group at (888) 760-6552 and speak with experienced counsel about a possible recovery of your investment losses. Soreide Law Group represents clients on a contingency fee basis and advances all costs. The firm has recovered millions of dollars for investors who have suffered losses due to misconduct of brokers and brokerage firms.
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