RAYMOND L LENT Settles with SEC for $1.1M

According to a recent article in Financial Advisor, the Securities and Exchange Commission (SEC) ordered investment advisor RAYMOND LAWRENCE LENT (RAYMOND L LENT, RAY LENT) and his San Rafael, California-based firm, Putney Financial Group, to pay a settlement of approximately $1.1 million for alleged breaches of fiduciary duty and failure to provide accurate disclosures. Ray Lent has accepted the terms without admitting or denying the charges.

RAYMOND L LENT was doing business as The Putney Financial Group, Registered Investment Advisors during the time period in question, and according to an FA IQ article, he allegedly recommended his clients buy variable annuities from insurers paying upfront sales commissions to Putney's affiliated broker, Portsmouth Financial Services, and to Lent, as a registered representative of Portsmouth.

RAYMOND L LENT and his firm are charged with allegedly recommending to advisory clients various variable annuities that paid up-front sales commissions of 6.8% of invested assets, on average, to Lent and the brokerage firm he co-owns, Portsmouth Financial Services, without “fully and fairly disclosing the related conflicts of interest,” according to the legal documents. According to the FA article, Lent and his firm allegedly kept recommending the more expensive commission-based versions without adequately analyzing whether they were in the clients’ best interests, and without disclosing a conflict of interest. This allegedly occurred between April 2016 and October 2021 and violated the firm’s “duty of care to its advisory clients,” the SEC charged.

The FA article goes on to say that besides recommending expensive and self-dealing annuities, the firm is accused of having clients use cash-sweep money market funds for uninvested cash that charged revenue-sharing payments and were more expensive than other available funds of the same type. According to the settlement, the revenue-sharing payments were not disclosed to the clients.

According to FINRA's BrokerCheck (available to the public on FINRA’s website), RAYMOND L LENT has been in the securities industry for 48 years and was listed with 7 firms.  Lent has 7 disclosures on his FINRA CRD report, six are “Customer Disputes,” all have settled. The significance of Lent’s FINRA Customer Complaints is underscored in FINRA NOTICE to MEMBERS 03-49. FINRA conducted a review of the CRD’s of all registered representatives, only .41% had been the subject of 3 or more customer complaints. In other words RAYMOND L LENT’s customer complaints rank him in the top one-hundredth percent of all registered representatives for customer complaints. 

The Financial Advisor article states that in its most recent Form ADV, dated March 28, 2024, Putney Financial Group reported having approximately $177 million in regulatory assets under management and more than 1,000 client accounts. The SEC has instituted a cease-and-desist order against Lent and Putney Financial for violating their duty of care and multiple compliance deficiencies. Included are, paying the SEC a disgorgement of $707,129.58, prejudgment interest of $183,236.60, and civil penalties of $175,000, they must also make corrections to disclosure documents, determine whether any clients would be better served with lower cost products, and notify clients who were financially harmed.

RAYMOND L LENT has been registered with the following firm since 7/26/2010:

PORTSMOUTH FINANCIAL SERVICES

100 Smith Ranch Road Suite 110
SAN RAFAEL, CA 94903

If you or a loved one have experienced financial losses due to the actions or recommendations of RAYMOND L LENT of PORTSMOUTH FINANCIAL SERVICES, and/or The Putney Financial Group, contact Soreide Law Group and speak to an experienced securities lawyer at no cost regarding the possible recovery of your investment losses through a FINRA arbitration at:  888-760-6552.

Soreide Law Group represents our clients nationwide before FINRA on a contingency fee basis, no fee to you if no recovery.