Dec 11, 2025

Edward Jones Financial Advisor Jeremy Bouwman Under Investigation For Unsuitable Investment Recommendations in FINRA Customer Complaints

Jeremy Lee Bouwman (CRD# 5530522) is a financial advisor and stockbroker with Edward Jones in Austin, Texas, and our firm is investigating customer complaints alleging unsuitable investment recommendations and related sales practice violations. Financial Advisor’s Career History According to his FINRA BrokerCheck report, Jeremy Lee Bouwman has been employed by Edward Jones since May 2008, working as a financial advisor in the firm’s Austin, Texas branch offices. He first became registered with Edward Jones as a General Securities Representative in June 2008 and later qualified as an Investment Adviser Representative in Texas in October 2009. Over the years, he has obtained registrations with multiple self-regulatory organizations, including FINRA, the New York Stock Exchange, NYSE American, and the Nasdaq Stock Market, and has been licensed as an agent in numerous states, including Texas, Colorado, Georgia, Florida, California, and others. Since entering the securities industry, Bouwman’s entire reported investment-related employment history has been with Edward Jones, where he continues to service retail customers through the firm’s Austin-area branch locations. Jeremy Lee Bouwman Fraud Allegations and Investor Complaints Explained FINRA BrokerCheck for Jeremy Lee Bouwman (CRD# 5530522) discloses three customer disputes, including one settled complaint and two written complaints that were denied after firm investigations. 2022 Customer Dispute – Alleged Unsuitable Use of Home Loan Proceeds In May 2022, a customer submitted a written complaint alleging that Bouwman’s advice to take funds from a home loan and invest the proceeds in the market was not suitable. The account involved was described as a self-directed, fee-based in-house account. The client claimed damages of $72,160.62. After Edward Jones investigated, the complaint was resolved on August 4, 2022, through a monetary settlement of $45,844.82, of which Bouwman was required to personally contribute $4,584.48. The BrokerCheck report classifies this event as a “Customer Dispute – Settled.” 2015 Complaint – Alleged Poor Recommendation to Purchase Kinder Morgan Stock In December 2015, a separate customer alleged that Bouwman provided a “poor recommendation” to purchase Kinder Morgan stock in November 2015. The customer alleged damages of $5,000 in connection with the common stock investment. Edward Jones reviewed the complaint and, after its internal investigation, denied the claim on January 5, 2016. BrokerCheck reflects that no settlement was paid and that both the settlement amount and individual contribution amount were $0. 2013 Complaint – Alleged Poor Advice Regarding Mutual Fund Sales In December 2013, another customer complaint was filed alleging that, from August 26, 2013 to September 27, 2013, the sale of mutual funds recommended by Bouwman constituted poor advice or a poor recommendation. The customer alleged damages of approximately $5,500 related to mutual fund transactions. Following the firm’s investigation, Edward Jones denied the claim on December 16, 2013. BrokerCheck shows a settlement amount of $0 and no individual contribution by Bouwman. Summary of Disclosed Customer Disputes Based on the FINRA BrokerCheck report, Jeremy Lee Bouwman has the following customer dispute history: While two of the complaints were denied with no compensation to the customers, the 2022 matter resulted in a substantial settlement payment. Investors should understand that a settlement does not necessarily mean the broker admitted wrongdoing, and denied claims may still involve significant losses that could be recoverable in FINRA arbitration depending on the facts and applicable law. These allegations, particularly those involving advice to borrow against a home and invest the proceeds in the securities markets, raise serious suitability and risk-management concerns that warrant careful review by experienced securities counsel. To obtain a copy of Jeremy Lee Bouwman’s FINRA BrokerCheck report, visit this link. Robert Wayne Pearce Is Committed to Recovering Your Investment Losses FINRA Rule 2111, the Suitability Rule, requires that a broker have a reasonable basis to believe that any recommended transaction or investment strategy is suitable for the customer in light of the client’s age, financial situation, risk tolerance, investment experience, and objectives. In the complaints involving advice to take funds from a home loan and invest the proceeds in the market, as well as the recommendations to purchase individual securities and mutual funds, regulators and arbitrators will focus on whether Bouwman’s recommendations exposed customers to an unreasonable level of risk relative to their overall financial profile and whether the use of borrowed funds magnified those risks in violation of Rule 2111. FINRA Rule 2090, the Know Your Customer Rule, obligates brokers to use reasonable diligence to know and retain the essential facts concerning every customer and the authority of each person acting on a customer’s behalf. In the context of the customer disputes involving home equity borrowing and securities purchases, the question becomes whether Bouwman adequately understood each investor’s financial condition, debt obligations, and ability to bear losses before recommending strategies that involved leveraging a home to invest in the markets or concentrating assets in particular securities or mutual funds. A failure to gather or properly consider this information may constitute a violation of Rule 2090. FINRA Rule 2010 requires brokers to observe high standards of commercial honor and just and equitable principles of trade in the conduct of their business. Even if a particular recommendation is not found to be outright fraudulent, patterns of unsuitable advice, poor recommendations, or disregard for a customer’s best interests can be viewed as inconsistent with the ethical obligations embodied in Rule 2010. The allegations that Jeremy Lee Bouwman recommended risky strategies involving home loan proceeds and other investments that may not have aligned with customers’ needs could, if proven, support a finding that he failed to live up to the standards of professional conduct required by FINRA. For over 45 years, Robert Wayne Pearce has helped investors recover losses caused by broker fraud, negligence, and unsuitable recommendations. His firm, The Law Offices of Robert Wayne Pearce, P.A., represents clients nationwide on a no-recovery, no-fee basis. Call (800) 732-2889 or email pearce@rwpearce.com for a free case review with an experienced securities attorney.

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Dec 10, 2025

Aurora Securities Broker Roger Bowlin Under Investigation For Unsuitable Real Estate Securities Recommendations in FINRA Customer Disputes

Our firm is investigating Aurora Securities broker and investment adviser Roger William Bowlin (CRD# 1905652) of Kirkland, Washington for potential investment-related misconduct. Financial Advisor’s Career History According to publicly available FINRA BrokerCheck records, Roger William Bowlin has worked in the securities industry since 1988 and is currently registered as a General Securities Representative with Aurora Securities (CRD# 46147) and as an Investment Adviser Representative with Secure Asset Management, L.L.C. (CRD# 144046). Both firms list office locations at 650 NE Holladay Street, Suite 1600, Portland, Oregon, while Bowlin’s Form U4 employment history identifies his role with these firms as based in Kirkland, Washington. Bowlin has been registered with Aurora Securities since April 30, 2021, and with Secure Asset Management, L.L.C. since June 4, 2021. Before joining these firms, he was associated with Concorde Asset Management, LLC and Concorde Investment Services, LLC from 2016 to 2021, Independent Financial Group, LLC from 2008 to 2016, ePlanning Securities, Inc. and ePlanning Advisors Inc. from 2007 to 2008, Pacific West Financial Consultant Inc. and Pacific West Securities, Inc. from 2000 to 2007, Pacific Harbor Securities, Inc. from 1994 to 2000, Investment Management & Research, Inc. from 1993 to 1994, Laney & Company from 1990 to 1992, and Halliday Capital Partners, Inc. from 1988 to 1989. In addition to his brokerage and advisory roles, Bowlin reports multiple outside business activities, including ownership and involvement in real estate-related entities such as Real Estate Transition Solutions, LLC and various “Riverwalk” real estate rental properties, as well as a securities DBA, R.W. Bowlin Investment Solutions, Inc. Roger William Bowlin Fraud Allegations and Investor Complaints Explained FINRA BrokerCheck currently discloses two pending customer disputes involving Roger William Bowlin, both arising from investments in real estate securities and filed as FINRA arbitration claims against Aurora Securities. The complaints allege unsuitable recommendations, mismanagement of customer accounts, and substantial investment losses, with claimed damages ranging from $1,000,000 to $5,000,000. While these matters are still pending and have not been adjudicated, they raise serious concerns about Bowlin’s recommendations and the handling of real estate securities within customer accounts. Investors should understand that these are allegations only and may ultimately be resolved in Bowlin’s favor, dismissed, or settled without any admission of wrongdoing. Below is a summary of the pending disclosure events reported on BrokerCheck: These pending disputes suggest that investors claim they suffered large losses in real estate securities due to allegedly unsuitable recommendations and account mismanagement. Both cases are in the early stages of the FINRA Dispute Resolution process, and no findings have been made regarding liability or damages. To obtain a copy of Roger William Bowlin’s FINRA BrokerCheck report, visit this link. Robert Wayne Pearce Is Committed to Recovering Your Investment Losses FINRA Rule 2111, commonly known as the Suitability Rule, requires brokers to have a reasonable basis to believe that any recommended investment or strategy is suitable for a customer based on that customer’s investment profile, including financial situation, risk tolerance, objectives, and time horizon. In the pending customer disputes against Roger William Bowlin, investors allege unsuitable recommendations in real estate securities and mismanagement of their accounts, with claimed damages reaching into the millions of dollars. If an arbitration panel ultimately finds that Bowlin recommended complex or illiquid real estate securities without adequately considering his customers’ profiles or the risks involved, the panel could determine that such conduct violated FINRA Rule 2111’s suitability obligations. FINRA Rule 2010 requires associated persons to “observe high standards of commercial honor and just and equitable principles of trade.” This rule is broad and often cited when regulators or arbitration panels evaluate allegations of mismanagement, unfair dealing, or other misconduct in customer accounts. The claims that Bowlin mismanaged accounts and recommended unsuitable real estate securities could, if proven, support findings that he failed to meet the high standards imposed by Rule 2010—particularly if the panel concludes that material risks were not fully disclosed, or that customers were not treated fairly in connection with these transactions. FINRA Rule 3110 governs supervision and requires member firms like Aurora Securities to establish and maintain a system reasonably designed to achieve compliance with securities laws and FINRA rules. Although Rule 3110 primarily addresses the firm’s responsibilities, it is highly relevant in cases involving large claimed losses in specific product types like real estate securities. If the pending arbitrations reveal patterns of unsuitable recommendations, inadequate review of real estate deals, or failure to address red flags in Bowlin’s business, the supervising firm may face claims that its supervisory system and procedures were deficient under Rule 3110. Those supervisory shortcomings, in turn, could strengthen investors’ ability to recover losses from both the broker and the firm. The Law Offices of Robert Wayne Pearce, P.A. is a nationally recognized securities law firm representing investors in FINRA arbitration and securities fraud cases on a contingency fee basis. Robert Wayne Pearce, the founding attorney, has more than 45 years of experience recovering millions for victims of broker misconduct and investment fraud. He previously defended major brokerage firms and now uses that insight to protect investors nationwide. To discuss your case directly with Mr. Pearce, call (800) 732-2889 or email pearce@rwpearce.com for a free consultation.

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Dec 10, 2025

Prospera Financial Services Broker and Investment Adviser Nicholas Olivas Under Investigation For Unauthorized Trading, Failure to Follow Trade Instructions, and Mismanagement FINRA Complaints

Our firm is investigating Prospera Financial Services, Inc. broker and investment adviser Nicholas David Olivas (CRD# 6803146) of Irvine, California for potential investment-related misconduct. Financial Advisor’s Career History According to FINRA BrokerCheck, Nicholas David Olivas (CRD# 6803146) has been licensed in the securities industry since 2017 and has worked as both a broker and investment adviser in California and Texas. His registration and employment history includes: In addition to his brokerage and advisory roles, Mr. Olivas has disclosed an outside business activity doing business as Bregma Private Wealth, an Irvine, California–based wealth management practice where he serves as owner and advisor. Nicholas David Olivas Fraud Allegations and Investor Complaints Explained FINRA BrokerCheck for Nicholas David Olivas reports two customer disputes and one employment separation after allegations. While these matters were ultimately either withdrawn or denied and there has been no regulatory finding of fraud, they provide important context for investors evaluating how their accounts may have been handled. 2025 LPL Financial Customer Complaint – Alleged Failure to Follow Trade Instructions In August 2025, a customer submitted a written complaint related to Mr. Olivas’s conduct while he was registered with LPL Financial LLC: This complaint, if proven, would be consistent with allegations that a broker failed to execute a customer’s orders as directed, which can raise concerns regarding adherence to customer instructions and standards of fair dealing, even when the matter is later withdrawn. 2023 Raymond James Customer Complaint – Alleged Unauthorized Options Trading and Mismanagement FINRA BrokerCheck also discloses a 2023 written customer complaint involving options trading while Mr. Olivas was registered with Raymond James & Associates, Inc.: Although this complaint was denied by the firm and closed with no payment, the allegations of unauthorized options trading and account mismanagement are serious, particularly given the complexity and risk of options strategies. 2025 Termination from LPL Financial – Use of Unapproved Email BrokerCheck further reports that LPL Financial LLC discharged Mr. Olivas in November 2025 following internal allegations related to firm policy violations: While this termination disclosure does not itself allege customer harm or trading losses, it indicates that the firm believed Mr. Olivas was conducting business communications outside of its approved systems—conduct that can raise concerns about supervision, recordkeeping, and transparency. Summary of Disclosed Events Taken together, the BrokerCheck report for Nicholas David Olivas lists: Investors should understand that these are allegations, not findings of liability; however, multiple disclosures of unauthorized trading, mismanagement, and failure to follow customer instructions may indicate patterns that merit further investigation on behalf of investors who experienced similar losses. To obtain a copy of Nicholas David Olivas’s FINRA BrokerCheck report, visit this link. Robert Wayne Pearce Is Committed to Recovering Your Investment Losses In cases where customers allege that a broker ignored explicit trading instructions or executed unauthorized options trades, FINRA Rule 2010—Standards of Commercial Honor and Principles of Trade—is often central. This rule requires brokers to observe “high standards of commercial honor and just and equitable principles of trade” in all their business conduct. When a customer claims that an advisor failed to follow their trade instructions or entered transactions without authorization, regulators and arbitrators frequently evaluate whether that conduct falls below the professional standards embodied in FINRA Rule 2010, even if a firm has not admitted wrongdoing or the complaint was withdrawn or denied. In addition, allegations of unauthorized options trades and mismanagement often implicate FINRA Rule 3260, which governs discretionary accounts and the authorization of transactions by customers. Rule 3260, together with related supervisory rules, requires that brokers obtain proper written authority and, where appropriate, firm approval for discretionary trading. Even in non-discretionary accounts, a broker must have the customer’s prior consent for each transaction. When a customer asserts that options trades were made without authorization—as in the complaint reported against Mr. Olivas—counsel will typically investigate whether there was any true discretionary authority, whether the trades matched the customer’s instructions, and whether the firm adequately supervised the account to prevent unauthorized activity. Finally, customer allegations of “mismanagement” and substantial losses in an options strategy can raise issues under FINRA Rule 2111, the Suitability rule. Rule 2111 requires that brokers have a reasonable basis to believe that a recommended transaction or investment strategy is suitable for the customer based on that customer’s investment profile—including factors such as age, financial situation, risk tolerance, and investment objectives. Concentrated options positions, frequent trading, or complex strategies can be unsuitable for many conservative or income-oriented investors. Even where a complaint is ultimately denied or withdrawn, attorneys evaluating potential claims will consider whether the options trading at issue was appropriate for the client’s profile and whether it may have violated suitability obligations under FINRA Rule 2111. For over 45 years, Robert Wayne Pearce has helped investors recover losses caused by broker fraud, negligence, and unsuitable recommendations. His firm, The Law Offices of Robert Wayne Pearce, P.A., represents clients nationwide on a no-recovery, no-fee basis. Call (800) 732-2889 or email pearce@rwpearce.com for a free case review with an experienced securities attorney.

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Dec 10, 2025

Bankers Life Securities Broker Daniel Corey Under Investigation For Unsuitable Annuity and Insurance Recommendations in FINRA Customer Complaints

Daniel Patrick Corey (CRD# 6319568) is a financial advisor and stockbroker currently registered with Bankers Life Securities, Inc. and Bankers Life Advisory Services, Inc. in Portland, Oregon, and our firm is investigating him for potential investment-related misconduct involving alleged unsuitable annuity and insurance recommendations and related sales practice violations. Financial Advisor’s Career History Daniel Patrick Corey has spent his securities and insurance career primarily with the Bankers Life family of companies and a prior broker-dealer affiliate. This history reflects an extended focus on insurance, annuity, and securities products marketed to retail investors through the Bankers Life platform. Daniel Patrick Corey Fraud Allegations and Investor Complaints Explained According to Corey’s FINRA BrokerCheck report, his public record includes one criminal disclosure and three customer dispute disclosures, two of which resulted in monetary settlements paid to customers and one that was denied without payment. Criminal Disclosure – 2000 Theft Conviction Corey’s record reflects a misdemeanor theft conviction from March 2000 in Multnomah County Circuit Court, Oregon. Although this criminal matter predates Corey’s securities career, it appears on his regulatory record and may be relevant to investors assessing his background. 2019 FINRA Arbitration Alleging Unsuitable Equity-Indexed Annuities and Life Insurance In September 2019, customers filed a Statement of Claim for arbitration with FINRA naming Bankers Life Securities, Inc. and Bankers Life and Casualty Company as respondents and alleging misconduct by Corey relating to annuity and insurance recommendations. The customers alleged that Corey: The customers did not specify an exact dollar amount of damages in their claim but referenced the surrender charges and alleged harm from the annuity and insurance sales. BLC ultimately chose to settle the matter, and the arbitration was resolved with a payment of $24,640.51 to the customers on or about December 7, 2020. Corey did not contribute personally to the settlement according to the disclosure. In a broker statement, Corey maintained that: 2021 Customer Complaint Alleging Misrepresentation of Guaranteed Lifetime Income Annuities In March 2021, another customer submitted a written complaint to Bankers Life and Casualty Company regarding Guaranteed Lifetime Income Annuities (GLIAs) purchased in December 2017 and March 2018. The customer alleged that Corey, acting as her financial representative: Key details from the disclosure include: The firm reported that it determined the annuities were suitable, that all material terms were disclosed, and that no relief was warranted. The complaint nonetheless appears on Corey’s regulatory record because the products were funded with proceeds from securities recommended by a registered representative of the firm. 2022 Customer Complaint and Settlement Over Whole Life Policies and Premium Bonus Indexed Annuity In a written complaint received on March 14, 2022, customers alleged that Corey: The customers claimed their income was insufficient to support the new premiums and sought to cancel the policies and recover all funds. Key financial details: Although the firm concluded the life insurance policies and annuity were suitable, it agreed to a partial refund as an “accommodation” to the customers. The complaint is reportable because the underlying funding source was a securities account managed through the firm. Summary of Disclosures Corey’s BrokerCheck report currently reflects the following: In light of these disclosures, investors who purchased annuities or life insurance products after liquidating securities on Corey’s recommendation may have potential claims for unsuitability, misrepresentation, or other sales practice violations under FINRA rules and state securities laws. To obtain a copy of Daniel Patrick Corey’s FINRA BrokerCheck report, visit this link. Robert Wayne Pearce Is Committed to Recovering Your Investment Losses FINRA Rule 2111 (the Suitability Rule) requires brokers to have a reasonable basis to believe that any investment or strategy they recommend is suitable for the customer based on the customer’s investment profile, including financial status, tax status, investment objectives, risk tolerance, liquidity needs, and time horizon. In Corey’s case, allegations that he recommended customers surrender existing annuities and incur substantial surrender charges, concentrate a high percentage of their liquid net worth in a Premium Bonus Indexed Annuity, and take on additional whole life insurance premiums that their income allegedly could not sustain raise serious suitability concerns under Rule 2111. When a broker advises investors to replace existing products and lock up assets in long-term annuities with significant surrender charges, FINRA expects the broker to demonstrate a well-documented, customer-specific suitability analysis, which investors may argue was lacking here. FINRA Rule 2010 requires brokers to observe high standards of commercial honor and just and equitable principles of trade. Even when products are technically permissible, recommending transactions that generate commissions at the expense of the client’s interests, involve inadequately explained surrender charges, or are based on misleading or incomplete descriptions of product terms can violate Rule 2010. The criminal theft conviction on Corey’s record and the customer allegations of misrepresentation and commission-driven recommendations in connection with annuities and life insurance policies provide a basis for investors to argue that his conduct failed to meet FINRA’s ethical standards, particularly if evidence shows that he placed firm or personal compensation ahead of the customers’ best interests. FINRA Rule 3110 imposes strict supervisory obligations on brokerage firms, requiring them to establish and enforce written supervisory procedures designed to ensure compliance with securities laws and FINRA rules. Although Rule 3110 primarily targets the firm, it shapes the environment in which brokers like Corey operate. When a broker repeatedly recommends complex annuity and insurance strategies funded by the liquidation of securities, firms must supervise those recommendations, review replacements of existing annuities, monitor patterns of high commission or high surrender-charge transactions, and intervene where necessary. Investors may allege that Bankers Life Securities and related entities failed to adequately supervise Corey’s sales practices, allowing potentially unsuitable annuity and insurance strategies to be implemented without sufficient oversight, in violation of Rule 3110. For over 45 years, Robert Wayne Pearce has helped investors recover losses caused by broker fraud, negligence, and unsuitable recommendations. His firm, The Law Offices of Robert Wayne Pearce, P.A., represents clients nationwide on a no-recovery, no-fee basis. Call (800) 732-2889 or email pearce@rwpearce.com for a free case review with an...

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Dec 10, 2025

Osaic Wealth, Inc. Financial Advisor Lei Wang Under Investigation for Customer Disputes Alleging Misrepresentation in Managed Account and Variable Universal Life Policy Sales – FINRA Complaints

Our firm is investigating Osaic Wealth, Inc. broker and financial advisor Lei Wang (CRD# 2626500) of West Palm Beach, Florida for potential investment-related misconduct. Financial Advisor’s Career History Lei Wang has been in the securities industry since the mid-1990s and has worked for several national brokerage and insurance firms over the course of her career. Her current and prior registrations reported on FINRA BrokerCheck include: In addition to her brokerage registrations, Wang has passed the Series 7, Series 6, the Securities Industry Essentials (SIE) exam, and the Series 66 state law exam, and she has reported the Certified Financial Planner (CFP) designation. She also reports various insurance-related business activities, including the sale of fixed life and disability insurance, fixed and indexed annuities, and long-term care insurance. Lei Wang Fraud Allegations and Investor Complaints Explained According to Lei Wang’s publicly available FINRA BrokerCheck report, she has two investment-related customer disputes disclosed on her record—one denied and one currently pending—arising from allegations of misrepresentation in connection with a managed account and a variable universal life (VUL) insurance policy. These disputes involve claims that Wang misrepresented the risks or performance characteristics of the recommended products, including a suggestion that a managed asset account could not lose value and allegations that a VUL policy purchased in 2023 was misrepresented. 2016 Customer Dispute – Managed Asset Account at Lincoln Financial Advisors In September 2016, while associated with Lincoln Financial Advisors Corporation, a customer filed a written complaint alleging that Wang misrepresented the nature and risk of a managed asset account opened in December 2013. This disclosure indicates that the customer believed the risks and potential for loss in the managed account were not accurately described, while the firm ultimately rejected those allegations and did not offer compensation. 2025 Pending Customer Complaint – Variable Universal Life Policy at Osaic Wealth, Inc. A second customer complaint remains pending and involves new allegations while Wang is associated with Osaic Wealth, Inc. Because this matter is still pending, there has been no finding of liability against Lei Wang or Osaic Wealth, Inc., and the allegations remain unproven. Investors should nonetheless be aware of the risk that similar misrepresentation issues may have affected other clients, especially with respect to complex insurance products like VUL policies. Summary of Reported Disclosures These disclosures do not, by themselves, prove wrongdoing. However, they raise important questions about whether clients were fully and fairly informed of the risks, costs, and performance characteristics of the recommended managed account and VUL policy. The customer disputes involving Lei Wang illustrate the types of misrepresentation and sales-practice issues that can lead to significant investor losses, particularly when clients are placed into managed accounts or complex insurance products without a clear understanding of downside risk. Investors who believe they were misled about the safety, performance guarantees, or costs of similar strategies should carefully review their accounts and policies and consider seeking legal advice. To obtain a copy of Lei Wang’s FINRA BrokerCheck report, visit this link. Robert Wayne Pearce Is Committed to Recovering Your Investment Losses FINRA Rule 2111, commonly known as the Suitability Rule, requires brokers and associated persons to have a reasonable basis to believe that any recommended investment strategy or product is suitable for the customer based on that customer’s investment profile—including age, risk tolerance, financial situation, and investment objectives. In the context of the complaints involving Lei Wang, the suitability rule may be implicated if a managed asset account or variable universal life policy was recommended to a client whose risk tolerance or financial needs were inconsistent with the product’s volatility, fees, or long-term obligations. If Wang represented that a managed account could not lose value or that a VUL policy had benefits that were not accurately described, and those recommendations were inconsistent with the client’s profile, FINRA Rule 2111 could provide a basis for investor claims if the allegations are proven. Investors can learn more about how this rule protects them in the firm’s discussion of FINRA’s Know Your Client and Suitability standards. FINRA Rule 2210 governs Communications with the Public and requires that all communications be fair and balanced and not omit any material facts or qualifications that would cause a statement to be misleading. This rule is particularly important when brokers describe managed accounts as “safe” or “guaranteed” or when they promote complex insurance products like VUL policies. In the complaints involving Wang, statements that a managed account would “only increase in value” or that a VUL was presented without full disclosure of risks, internal charges, or the potential for policy underperformance may raise concerns under Rule 2210. If the marketing or explanations given to the customer failed to disclose material risks or overstated potential benefits, those communications could be considered misleading under FINRA standards if the allegations are ultimately substantiated. FINRA Rule 2010 requires brokers and associated persons to observe high standards of commercial honor and just and equitable principles of trade. This is a broad conduct rule that often applies when alleged misrepresentations, omissions, or other unethical sales practices are at issue—even if no specific product rule is cited. In Lei Wang’s case, if a fact-finder were to determine that she knowingly or recklessly misrepresented the risk of loss in a managed account or the characteristics of a VUL policy, such conduct could be viewed as inconsistent with the high standards of honesty and fairness required by Rule 2010. Even where a complaint is denied or remains pending, investors should understand that this rule gives FINRA and arbitrators wide latitude to hold brokers accountable when their conduct falls short of the ethical obligations imposed on registered representatives, as explained further in the firm’s overview of FINRA Rule 2010. For over 45 years, Robert Wayne Pearce has helped investors recover losses caused by broker fraud, negligence, and unsuitable recommendations. His firm, The Law Offices of Robert Wayne Pearce, P.A., represents clients nationwide on a no-recovery, no-fee basis. Call (800) 732-2889 or email pearce@rwpearce.com for a free case review with an experienced securities...

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Dec 10, 2025

Emerson Equity Broker John Ledesma Under Investigation For Real Estate Securities Misconduct in FINRA Complaints

Our firm is investigating Emerson Equity LLC broker and investment adviser John Paul Ledesma (CRD# 2379751) of Irvine, California for potential investment-related misconduct. Financial Advisor’s Career History According to publicly available FINRA BrokerCheck records, John Paul Ledesma has been registered as a General Securities Representative with Emerson Equity LLC (CRD# 130032) since May 6, 2021, working out of a branch office located at 9870 Research Drive, Suite 104, Irvine, California. Before joining Emerson Equity LLC, Ledesma was associated with several other securities firms. He was registered with Capulent LLC in Irvine, California from January 2019 to May 2021 and with Sutter Capital Partners, LLC from March 2019 to May 2021. Earlier in his career, he briefly worked with Independent Financial Group, LLC in Mission Viejo, California in 2017 and previously held a registration with Atlanta-One, Inc. in the 1990s. In addition to his brokerage work, FINRA records show that Ledesma has reported multiple outside business activities, including acting as an independent real estate broker through John Paul Ledesma Real Estate Brokerage and conducting investment-related business under the trade name “DBA Beacon 1031” in connection with his securities business at Emerson Equity. John Paul Ledesma Fraud Allegations and Investor Complaints Explained FINRA BrokerCheck discloses three pending customer disputes involving John Paul Ledesma, all arising from sales of real estate securities and filed as FINRA arbitration claims. Each matter remains unresolved and is reported as “pending,” with investors seeking substantial but unspecified compensatory and punitive damages, along with other forms of relief. For many investors, this is the primary avenue to pursue recovery through FINRA arbitration rather than traditional court litigation. The pending customer disputes generally allege that Ledesma and his firm violated federal and state securities laws, breached contractual and fiduciary duties to investors, and acted negligently and grossly negligently in connection with recommending and selling real estate securities. In at least one case, the complaint alleges that trades were placed between 2022 and 2023, indicating that the alleged misconduct occurred relatively recently while Ledesma was with Emerson Equity LLC. Below is a summary of the three pending disclosure events as reported on BrokerCheck: These disclosures reflect serious, yet still unproven, allegations about how real estate securities were marketed, recommended, and sold to multiple investors across several states. Investors should understand that the disputes remain pending and may ultimately be resolved in favor of Ledesma and his firm, dismissed, or settled without any admission of wrongdoing. To obtain a copy of John Paul Ledesma’s FINRA BrokerCheck report, visit this link. Robert Wayne Pearce Is Committed to Recovering Your Investment Losses FINRA Rule 2111 (the Suitability Rule) requires brokers to have a reasonable basis to believe that any recommended investment or strategy is suitable in light of the customer’s investment profile—including age, financial situation, investment experience, risk tolerance, objectives, and liquidity needs. In the customer disputes involving John Paul Ledesma, investors allege that real estate securities were sold in violation of federal and state securities laws, and that he breached contractual and fiduciary duties while acting negligently and grossly negligently. If FINRA ultimately finds that he recommended complex, illiquid real estate securities to investors whose profiles did not support those risks, or without conducting adequate due diligence, that conduct could be deemed a violation of FINRA Rule 2111’s suitability requirements. FINRA Rule 2010 requires that all brokers “observe high standards of commercial honor and just and equitable principles of trade.” This broad rule is frequently cited when brokers are accused of fraud, misrepresentation, or other unethical practices in connection with securities sales. The allegations of common law fraud, breaches of fiduciary duty, and violations of federal and state securities laws in the Ledesma arbitrations suggest that customers believe he failed to live up to those standards when recommending and selling real estate securities through Emerson Equity LLC. If the arbitration panels conclude that he misrepresented risks, omitted material facts, or otherwise failed to deal fairly with customers, they could find violations of FINRA Rule 2010 based on the same course of conduct. FINRA Rule 3110 governs the supervisory obligations of brokerage firms and requires member firms to establish and maintain a system to supervise the activities of each associated person—like Ledesma—that is reasonably designed to achieve compliance with applicable securities laws and FINRA rules. While Rule 3110 primarily applies to the firm, it is highly relevant to the types of claims being asserted in these real estate securities cases. If Emerson Equity LLC failed to reasonably supervise recommendations, review complex product sales, or investigate red flags tied to Ledesma’s transactions, investors may pursue claims against both the broker and the firm to recover their losses. Findings that Ledesma’s recommendations violated suitability or fair dealing standards could support the argument that the firm’s supervisory systems under Rule 3110 were inadequate as applied to his business. The Law Offices of Robert Wayne Pearce, P.A. is a nationally recognized securities law firm representing investors in FINRA arbitration and securities fraud cases on a contingency fee basis. Robert Wayne Pearce, the founding attorney, has more than 45 years of experience recovering millions for victims of broker misconduct and investment fraud. He previously defended major brokerage firms and now uses that insight to protect investors nationwide. To discuss your case directly with Mr. Pearce, call (800) 732-2889 or email pearce@rwpearce.com for a free consultation.

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Dec 2, 2025

Arkadios Capital Broker and Investment Adviser Ronald York Jr. Under Investigation For Unsuitable Alternative Investment and Private Placement Recommendations FINRA Complaints

Our firm is investigating Arkadios Capital broker and investment adviser Ronald N. York Jr. (CRD# 4308987) of Wall, New Jersey for potential investment-related misconduct involving allegedly unsuitable alternative investments and private placement recommendations. Financial Advisor’s Career History Ronald N. York Jr. (CRD# 4308987) is currently registered as a broker with Arkadios Capital (CRD# 282710) and as an investment adviser representative with Arkadios Wealth Advisors (CRD# 288863). He has been associated with both firms since April 30, 2019, and works from a branch office located at 4814 Outlook Drive, Suite 104, Wall, New Jersey. York has spent his career in the securities industry working for a series of national and regional firms, including: York has passed the Securities Industry Essentials (SIE) exam, the Series 7 General Securities Representative exam, the NYSE Series 21 and 25 exams, and the Series 63 and 65 state law exams. He is currently licensed in numerous U.S. states and the District of Columbia through his Arkadios affiliations. In addition to his securities work, York has disclosed several other business activities, including a financial planning partnership (Foresight Financial Partners) in Wall, New Jersey, rental real estate in New Jersey, an insurance business, and a real estate consulting and management business. Ronald N. York Jr. Fraud Allegations and Investor Complaints Explained According to York’s publicly available FINRA BrokerCheck report, there are two investment-related customer disputes disclosed involving allegations of unsuitable recommendations in alternative investments and private placements—one settled and one pending. These customer disputes involve: FINRA and BrokerCheck emphasize that customer complaints and arbitration claims contain allegations only. They may be contested and can be resolved in favor of the broker or firm, or settled for business reasons without any admission of wrongdoing. 1. 2015 GPB Holdings Unsuitability Allegation – FINRA Arbitration, Settled One customer dispute reported on York’s record involves a claim tied to a 2015 investment in GPB Holdings, a high-risk, illiquid private offering structured as a DPP/LP interest. The client alleged that the recommendation was unsuitable in light of her investment profile. Key details from the disclosure include: In his BrokerCheck “Broker Statement,” York disputes the customer’s allegations, asserting that the client was an educated, experienced, accredited investor who understood the risks and had made numerous investments through the firm, several of which carried risk. 2. 2022 DST Private Placement Unsuitability Allegation – FINRA Arbitration, Pending A second customer dispute on York’s record is currently pending and involves a private placement structured as a Delaware Statutory Trust (DST). The claim arises from a transaction that allegedly occurred on or about February 1, 2022, while York was registered with Arkadios Capital. Key details include: Because this dispute is still pending, no findings have been made and no decision has been reached regarding the customer’s claims. Summary of Customer Disclosures For ease of reference, the customer dispute disclosures involving Ronald N. York Jr. can be summarized as follows: At this time, York’s BrokerCheck report reflects customer dispute disclosures only, and does not list any regulatory actions, criminal matters, terminations for cause, or separate financial event disclosures. In reviewing these complaints, our firm is focused on whether York and his firms properly evaluated each customer’s risk tolerance, financial objectives, investment experience, and need for liquidity before recommending high-risk, illiquid alternative investments such as GPB Holdings and DST private placements. To obtain a copy of Ronald N. York Jr.’s FINRA BrokerCheck report, visit this link. Robert Wayne Pearce Is Committed to Recovering Your Investment Losses Detailing what FINRA Rule 2010 (Standards of Commercial Honor and Principles of Trade) requires is also critical to understanding the standards that apply to York and his firms. Rule 2010 is a broad, catch-all provision that requires brokers and associated persons to “observe high standards of commercial honor and just and equitable principles of trade” in the conduct of their business. In practice, FINRA frequently charges Rule 2010 in conjunction with more specific rules. If a broker engages in unsuitable recommendations, fails to conduct adequate due diligence on offerings such as GPB or DST private placements, or disregards firm procedures designed to protect customers, FINRA can characterize that conduct as inconsistent with the high standards of commercial honor codified in Rule 2010. A finding that York or his firm placed their own financial interests—such as high commissions on alternative investments—ahead of customers’ best interests could therefore be viewed as a violation of Rule 2010, even if no separate fraud charge is brought. As applied to the complaints described above, if it were proven that York recommended high-commission, speculative products without regard to the customers’ true needs or risk tolerances, regulators or arbitrators could conclude that such conduct violated both the suitability standard (Rule 2111) and the broader fair-dealing obligations of Rule 2010. Finally, understanding FINRA Rule 2020 (Use of Manipulative, Deceptive or Other Fraudulent Devices) helps explain how misrepresentations and omissions can factor into investor claims involving private placements. Rule 2020 prohibits brokers from effecting transactions in, or inducing the purchase or sale of, any security by means of any manipulative, deceptive, or fraudulent device or contrivance. In many alternative investment and private placement cases, investors allege not only that the recommendations were unsuitable, but also that the broker misrepresented the risks, overstated the safety or income potential, or failed to disclose material facts about the issuer’s financial condition, conflicts of interest, fees, or liquidity constraints. If, for example, a customer was told that a GPB or DST investment was “safe,” “income-producing,” or “similar to a bond,” while the broker downplayed the possibility of substantial loss of principal or the inability to easily sell the investment, such misstatements or omissions could be characterized as deceptive conduct in violation of Rule 2020. In the complaints involving York, to the extent investors claim that critical facts about the GPB Holdings investment or the DST private placement were not fully explained—or that the risks were minimized in order to induce them to invest—those allegations may form the basis of a Rule 2020 theory in addition to suitability...

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Dec 2, 2025

Stifel, Nicolaus & Company, Incorporated Financial Advisor Timothy Darragh Under Investigation For Alleged Breach of Fiduciary Duty and Negligence in FINRA Customer Complaints

Our firm is investigating Stifel, Nicolaus & Company, Incorporated financial advisor Timothy Darragh (CRD# 1897635) of Chicago, Illinois for potential investment-related misconduct. Financial Advisor’s Career History Timothy Darragh has worked in the securities industry since the late 1980s and is currently registered as a broker and investment adviser representative with Stifel, Nicolaus & Company, Incorporated (CRD# 793). He has been registered with Stifel since February 25, 2016 and is based in the firm’s Chicago, Illinois branch office at One North Wacker, Suite 3400. Before joining Stifel, Mr. Darragh spent more than a decade at Credit Suisse Securities (USA) LLC (CRD# 816) in Chicago, Illinois, where he was registered as both a broker and investment adviser from January 2003 through March 2016. During part of that time (2014–2016), he also reported employment with Credit Suisse Lending LLC in Chicago. Prior to Credit Suisse, he was associated with Donaldson, Lufkin & Jenrette Securities Corporation (CRD# 7560) in both New York, New York and Jersey City, New Jersey from approximately 2001 to 2003, and with Chase Securities Inc. (CRD# 18718) in New York, New York from 2000 to 2001. Earlier in his career, Mr. Darragh was registered with Hambrecht & Quist LLC (CRD# 940) in San Francisco, California from 1996 to 2000, Alex. Brown & Sons Incorporated (CRD# 20) from 1992 to 1996, PaineWebber Incorporated (CRD# 8174) in Weehawken, New Jersey from 1989 to 1992, and Investors Center, Inc. (CRD# 14670) from 1988 to 1989. Timothy Darragh Fraud Allegations and Investor Complaints Explained According to FINRA’s BrokerCheck report, Timothy Darragh has two pending customer dispute disclosures involving his conduct while employed by Stifel, Nicolaus & Company, Incorporated. In an arbitration claim filed on August 4, 2025, claimants allege that Mr. Darragh and Stifel engaged in a variety of sales practice violations in connection with mutual fund investments. The customers claim breach of contract and warranties, promissory estoppel, violations of state securities statutes, violations of Regulation Best Interest, breach of fiduciary duty, and negligence. The matter is pending in a FINRA arbitration forum under Docket No. 25-01598, and the claimants seek approximately $100,000 in compensatory damages. In a separate civil action filed in Illinois state court, claimants allege that Mr. Darragh and Stifel engaged in misconduct related to alternative investments. The complaint alleges breach of fiduciary duty, negligence, unjust enrichment, violations of the Illinois Consumer Fraud and Deceptive Practices Act, and trust accounting issues. The case is pending in the Circuit Court of Cook County, Illinois under Docket No. 2025-CH-03834. Although no specific dollar amount is pleaded, Stifel has reported that it reasonably estimates potential damages of $5,000 or more arising from the alleged conduct. These matters remain pending, and no final findings of liability have been made. However, the allegations focus on whether Mr. Darragh’s recommendations and account management for mutual funds and alternative investments were suitable, in the customers’ best interests, and properly disclosed. For context, the current customer dispute disclosures reported for Timothy Darragh include: Investors who worked with Mr. Darragh at Stifel in mutual funds or alternative investments—particularly around the time periods referenced in these pending actions—may wish to review their accounts for signs of unsuitable recommendations, concentration in risky or illiquid products, or other red flags such as unexplained losses. To obtain a copy of Timothy Darragh’s FINRA BrokerCheck report, visit this link. Robert Wayne Pearce Is Committed to Recovering Your Investment Losses FINRA also enforces Rule 2010 (Standards of Commercial Honor and Principles of Trade), which requires associated persons to observe high standards of commercial honor and just and equitable principles of trade in the conduct of their business. Even when there is no specific rule directly on point, FINRA and arbitration panels may find that conduct violating state consumer protection statutes, involving unjust enrichment, or reflecting serious mishandling of client funds or trust accounting can also constitute a violation of Rule 2010. In the civil action involving the Illinois Consumer Fraud and Deceptive Practices Act and alleged trust accounting issues, investors may argue that the same facts that support state law claims also amount to a failure to meet FINRA’s broad standards of commercial honor and fair dealing, particularly if any misleading statements, omissions, or misuse of client funds are proven. In addition, allegations of misconduct involving mutual funds and alternative investments may implicate anti-fraud and fair-dealing principles embedded in FINRA Rule 2020 (Use of Manipulative, Deceptive or Other Fraudulent Devices) and related securities laws. Rule 2020 prohibits brokers from effecting any transaction or inducing the purchase or sale of any security by means of manipulative, deceptive, or other fraudulent devices or contrivances. When customers allege violations of Regulation Best Interest, breach of fiduciary duty, unjust enrichment, or deceptive practices, they may contend that the broker failed to fully disclose conflicts of interest, compensation structures, or material risks, and that such omissions or misrepresentations rise to the level of deceptive conduct under Rule 2020 and applicable law. Arbitrators and courts will evaluate whether the evidence supports those allegations and whether investors reasonably relied on the broker’s recommendations and disclosures. For over 45 years, Robert Wayne Pearce has helped investors recover losses caused by broker fraud, negligence, and unsuitable recommendations. His firm, The Law Offices of Robert Wayne Pearce, P.A., represents clients nationwide on a no-recovery, no-fee basis. Call (800) 732-2889 or email pearce@rwpearce.com for a free case review with an experienced securities attorney.

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Dec 2, 2025

Emerson Equity Broker Bruce Beetz Under Investigation For Unsuitable Investment Recommendations and Securities Fraud Allegations in FINRA Complaint

Our firm is investigating Emerson Equity LLC broker and certified financial planner Bruce Robert Beetz (CRD# 1527269) of Hollister, California for potential investment-related misconduct involving allegedly unsuitable recommendations in corporate debt and real estate securities. Financial Advisor’s Career History Bruce Robert Beetz (CRD# 1527269) is currently registered as a General Securities Principal and General Securities Representative with Emerson Equity LLC (CRD# 130032). He has been registered with Emerson Equity LLC since November 4, 2019 and is based out of a branch office in Hollister, California, with the firm’s main office in San Mateo, California. Beetz has spent decades in the securities industry. According to his BrokerCheck report, he was previously registered with: Beetz has passed multiple securities industry examinations, including the Series 7 General Securities Representative Exam, the Series 24 General Securities Principal Exam, and the Series 51 Municipal Fund Securities Principal Exam, and holds the Certified Financial Planner (CFP) designation. He is licensed in numerous states, including California, Arizona, Colorado, Florida, Nevada, and others. In addition to his brokerage activities, Beetz has disclosed an outside business activity through “Alchemy Investment Planning,” involving fixed insurance sales and related estate planning, stating that any securities-related business is conducted through his employing broker-dealer. Bruce Robert Beetz Fraud Allegations and Investor Complaints Explained Public records on FINRA BrokerCheck show four investment-related customer disputes involving Bruce Robert Beetz, all reported while he has been associated with Emerson Equity LLC. One complaint has been settled, and three customer disputes remain pending as of 2025. The disputes focus on allegations of unsuitable recommendations, misrepresentations and omissions, breaches of fiduciary duty, violations of federal and state securities laws, and violations of FINRA rules and “Best Interest” obligations. These events concern recommendations primarily in corporate debt and real estate securities, with investors alleging damages ranging up to $300,000 per complaint and requesting additional relief such as punitive damages, attorney’s fees, and “benefit of the bargain” or lost opportunity costs in the pending arbitrations. While these complaints are serious, investors should understand that many of the allegations remain unproven and could ultimately be denied, dismissed, or resolved without any finding of wrongdoing. Summary of Settled FINRA Customer Dispute According to BrokerCheck, Beetz disclosed the following settled customer dispute connected to his activities at Emerson Equity LLC: This case suggests that the investor claimed the recommended corporate debt securities did not fit the customer’s risk tolerance, investment objectives, or financial circumstances, and that the investments caused significant losses. The firm resolved the dispute by paying a settlement substantially lower than the damages alleged by the customer, with no out-of-pocket contribution reported from Beetz personally. Summary of Pending Written Customer Complaint One matter is reported as a pending written customer complaint involving alleged unsuitable recommendations in real estate securities: The customer asserts that Beetz recommended real estate-related investments that were inappropriate for their financial profile, leading to alleged six-figure losses. The matter remains unresolved and could be withdrawn, denied, or escalated to arbitration or litigation. Summary of Pending FINRA Arbitration – Corporate Debt Investments (Case No. 24-02486) Beetz also reports a pending FINRA arbitration that raises a wide range of sales-practice and legal claims tied to corporate debt products: In this case, the claimants are asking not only for compensatory losses but also additional monetary penalties and fees, indicating they believe the alleged misconduct was particularly egregious. The case is still pending and subject to adjudication before a FINRA arbitration panel. Summary of Pending FINRA Arbitration – Multi-State and Elder Abuse Allegations (Case No. 25-00150) A second pending FINRA arbitration raises even broader accusations stemming from investments in corporate debt securities during November 2020 and November 2021: These allegations suggest that multiple customers—possibly including senior or vulnerable investors—are seeking to recover what they believe they should have earned had they been placed in more suitable or less risky investments, as well as punitive relief based on alleged fraudulent conduct and elder abuse statutes. Bullet-Point Summary of FINRA Disclosures For quick reference, the key disclosures involving Bruce Robert Beetz currently reported on BrokerCheck include: In summary, investors have accused Bruce Robert Beetz of making unsuitable recommendations and engaging in misrepresentations and other alleged misconduct in connection with complex corporate debt and real estate-related investments. While one dispute has already resulted in a substantial settlement, three additional matters are ongoing and could impact investors who purchased similar products from Beetz at Emerson Equity LLC. Investors who believe they suffered losses in products recommended by Beetz—especially illiquid or higher-risk corporate debt or real estate securities—should review their accounts, gather documentation, and consider speaking with a securities attorney experienced in FINRA arbitration to evaluate potential claims. To obtain a copy of Bruce Robert Beetz’s FINRA BrokerCheck report, visit this link. Robert Wayne Pearce Is Committed to Recovering Your Investment Losses FINRA Rule 2111 is the industry’s Suitability rule. It requires brokers to have a reasonable basis to believe that a recommended transaction or investment strategy is suitable for the customer based on information obtained through reasonable diligence, including the customer’s age, financial situation, investment experience, objectives, and risk tolerance. When a broker recommends concentrated positions in corporate debt or real estate securities to investors who may need liquidity or who cannot afford substantial loss of principal, that conduct may violate Rule 2111. In the disputes described above, investors allege that Beetz recommended unsuitable corporate debt and real estate securities that exposed them to far more risk than they were willing or able to take, and that these recommendations were inconsistent with their financial needs and investment profiles. If a FINRA arbitration panel finds that the investments were unsuitable, it may determine that Beetz and his firm failed to comply with Rule 2111. FINRA Rule 2010 requires brokers to observe high standards of commercial honor and just and equitable principles of trade in the conduct of their business. This “catch-all” rule is frequently cited by regulators and arbitration panels when brokers engage in misleading sales practices, fail to disclose material risks, or otherwise treat customers unfairly....

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Dec 2, 2025

Landolt Securities Broker Donald McKiernan Under Investigation For Failure to Supervise GWG L Bond Misappropriation FINRA Customer Complaints

Our firm is investigating Landolt Securities, Inc. broker and investment adviser representative Donald Trendley McKiernan (CRD# 1305965) of Lake Bluff, Illinois for potential investment-related misconduct. Stockbroker’s Career History According to his FINRA BrokerCheck report, Donald Trendley McKiernan (CRD# 1305965) has been in the securities industry since 1984 and is currently registered with Landolt Securities, Inc. in Lake Bluff, Illinois, where he serves as CEO and holds multiple principal and representative registrations (including General Securities Principal and General Securities Representative). Over the course of his career, McKiernan has been registered with the following brokerage firms: Donald Trendley McKiernan Fraud Allegations and Investor Complaints Explained FINRA BrokerCheck for Donald Trendley McKiernan reports multiple customer disputes—both settled, denied, and pending—arising primarily from alleged misappropriation of customer funds by a former registered representative, Anthony Liddle, and related allegations that McKiernan failed to reasonably supervise that representative in connection with GWG L Bonds, annuities, alternative investments, and UTMA accounts. Although the alleged misappropriation was carried out by Liddle, customers have asserted claims against McKiernan for negligence, failure to supervise, and violations of the Wisconsin Uniform Securities Act, seeking recovery of hundreds of thousands of dollars in alleged losses. McKiernan denies wrongdoing and asserts that Liddle acted alone through his separate registered investment adviser firm. GWG L Bond & Alternative Investment Misappropriation – $110,000 Claim (Settled) One FINRA arbitration involved a customer who alleged that Anthony Liddle solicited her to purchase GWG Holdings, Inc. L Bonds, but instead of purchasing the investment, he allegedly misappropriated $110,000. The customer asserted claims against McKiernan for negligence/failure to supervise and violations of the Wisconsin Uniform Securities Act. Key details of this disclosure: Multiple Customers – $498,000 in Alleged Misappropriation (Settled) A second FINRA arbitration combined several customers’ claims involving GWG L Bonds, an annuity, an alternative investment, and UTMA accounts, again tied to alleged misconduct by Anthony Liddle and alleged supervisory failures by McKiernan. According to BrokerCheck: Denied Customer Complaint – $856,443 in Alleged Misappropriation BrokerCheck also reports a denied customer complaint involving additional allegations of misappropriation. Customers alleged that Liddle misappropriated $797,000 between March 4, 2021 and May 4, 2022, and asserted claims against McKiernan for negligence and failure to supervise. Details include: Pending FINRA Arbitration – GWG L Bond Losses Up to $500,000 Most recently, BrokerCheck discloses a pending FINRA arbitration in which a claimant alleges breach of contract, violation of state securities statutes, negligence, misrepresentation, and breach of fiduciary duty related to a June 2020 GWG L Bond investment. Key facts of the pending matter: These disclosures demonstrate that investors have accused McKiernan, in his supervisory capacity at Landolt Securities, Inc., of failing to reasonably supervise a representative whose alleged misappropriation and unsuitable recommendations caused significant losses in GWG L Bonds and other investments. At the same time, it is important to remember that FINRA BrokerCheck includes allegations that may be contested, unresolved, or unproven, and some matters have been denied or settled without an admission of wrongdoing. In conclusion, the claims reported on McKiernan’s BrokerCheck suggest that investors who purchased GWG L Bonds, annuities, alternative investments, or UTMA accounts through Anthony Liddle and Landolt Securities, Inc. may have potential FINRA arbitration claims for failure to supervise and related state-law violations against the supervising principals, including McKiernan. To obtain a copy of Donald Trendley McKiernan’s FINRA BrokerCheck report, visit this link: visit this link. Robert Wayne Pearce Is Committed to Recovering Your Investment Losses FINRA Rule 2010 requires that members and associated persons “observe high standards of commercial honor and just and equitable principles of trade.” This rule is broadly applied whenever a broker’s or supervisor’s conduct is considered unethical, dishonest, or inconsistent with fair dealing—even if it does not violate a more specific rule. In the McKiernan-related disputes, investors claim that the firm’s and supervisor’s handling of GWG L Bond and other transactions allowed misappropriation to occur and persist, potentially falling short of the high ethical standard required by Rule 2010. When misappropriation, unsuitable recommendations, or serious supervisory lapses occur, panels often treat such conduct as inconsistent with “high standards of commercial honor,” and a finding of liability under Rule 2010 may accompany or follow a finding under Rule 3110. FINRA Rule 2111 (Suitability) obligates brokers to have a reasonable basis to believe a recommended transaction or investment strategy is suitable for the customer based on the customer’s investment profile (age, financial situation, investment objectives, risk tolerance, etc.). Even though many of the claims against McKiernan center on supervision rather than direct sales, the underlying investments—GWG L Bonds, annuities, and alternative products—raise classic suitability issues. In arbitrations arising from these types of products, investors often argue that: Where a supervising principal is named, claimants may contend that the principal’s failure to monitor suitability red flags and enforce product-specific supervisory guidelines contributed to violations of Rule 2111, even if the principal did not personally recommend the investments. For over 45 years, Robert Wayne Pearce has helped investors recover losses caused by broker fraud, negligence, and unsuitable recommendations. His firm, The Law Offices of Robert Wayne Pearce, P.A., represents clients nationwide on a no-recovery, no-fee basis. Call (800) 732-2889 or email pearce@rwpearce.com for a free case review with an experienced securities attorney.

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