Our firm is investigating former Raymond James Financial Services, Inc. broker and financial advisor H. Todd Roggen (CRD# 721463) of Houston, Texas, for potential investment-related misconduct involving allegedly unsuitable private placement investments and other sales practice violations.
Financial Advisor’s Career History
According to his FINRA BrokerCheck report, H. Todd Roggen entered the securities industry in 1980 and has spent more than four decades working at a series of national and regional firms.
Over the course of his brokerage career, Mr. Roggen was previously registered with the following broker-dealers:
- Rotan Mosle Inc. (CRD# 727) from December 1980 to February 1983
- Cowen & Co. (CRD# 1541) from January 1983 to February 1984
- Cowen Securities Inc. (CRD# 8531) from February 1984 to December 1986
- Prudential Securities Incorporated (CRD# 7471) from December 1986 to July 1992
- First Union Securities, Inc. (CRD# 19616) from July 1992 to January 2001
- UBS Financial Services Inc. (CRD# 8174) from January 2001 to June 2010
- Raymond James Financial Services, Inc. (CRD# 6694) in Houston, Texas, from June 2010 to November 2024
His employment history also reflects that he has worked as a financial advisor with Raymond James Financial Services Advisors, Inc. in Houston, and more recently as a financial advisor with MGO OneSeven DBA HTR Wealth Management, while also engaging in several insurance-related and other business activities.
Although he is currently no longer registered as a broker with FINRA, he continues to work in the investment advisory space through an affiliated registered investment adviser.
H. Todd Roggen Fraud Allegations and Investor Complaints Explained
FINRA BrokerCheck discloses that H. Todd Roggen has eight customer dispute disclosures, including one pending complaint, multiple settled cases, and an older arbitration award in favor of a customer. These matters involve allegations of misrepresentation, unsuitable investments, auction rate securities, government debt securities, and large purchases of preferred stock.
Pending 2025 Raymond James Private Placement Complaint
- Firm when conduct occurred: Raymond James Financial Services, Inc.
- Product type: Real estate security / private placements
- Allegations: The client alleges that Mr. Roggen recommended two unsuitable private placement investments and improperly enticed him to make those investments. Alleged activity dates span March 25, 2021 through March 24, 2025.
- Damages: Unspecified; the firm estimates the claimed loss is at least $5,000.
- Status: Customer dispute pending; written complaint received May 14, 2025.
This pending matter focuses on allegedly unsuitable private placement investments—an area where investors face heightened risks of illiquidity and loss, and where firms and brokers must adhere to strict suitability and disclosure standards. Investors with similar private placement losses may also have claims related to private placement fraud.
1990 Arbitration Award Related to Misrepresentation and Unsuitability
- Type of disclosure: Customer dispute – award/judgment
- Firm when conduct occurred: Cowen & Company, Inc.
- Allegations: Misrepresentations, unsuitability, and failure to disclose full information regarding investments, with the customer initially seeking $500,000 plus interest and punitive damages.
- Alleged damages: Approximately $75,000 in actual account losses for trades between 1983 and 1985.
- Outcome: A National Association of Securities Dealers (NASD) arbitration panel entered an award to the customer on December 4, 1990, in the amount of $251,978.50, and the award was later upheld by the U.S. District Court for the Southern District of Texas, Houston Division (Case No. H-86-4247).
This award reflects a finding in favor of the customer on claims that included misrepresentation, unsuitability, and lack of adequate disclosure.
Lehman Brothers Preferred Stock Complaints and Settlements (2008–2010)
Several customer disputes involve concentrated purchases of Lehman Brothers preferred stock shortly before Lehman’s collapse:
- FINRA Arbitration 09-05906
- Firm: UBS Financial Services Inc.
- Allegations: Misrepresentations and unsuitable recommendations to purchase Lehman preferred stock in February 2008.
- Alleged damages: $250,000.
- Outcome: Settled on November 17, 2010 for $90,000; no personal contribution reported by Mr. Roggen.
- FINRA Arbitration 09-05907
- Firm: UBS Financial Services Inc.
- Allegations: Similar allegations of misrepresentation and unsuitable recommendations involving Lehman preferred stock in February 2008.
- Alleged damages: $125,000.
- Outcome: Settled on November 17, 2010 for $40,000, with no individual contribution.
- FINRA Arbitration 08-03887
- Firm: UBS Financial Services Inc.
- Allegations: Misrepresentations and unsuitable recommendations to make large purchases of Lehman preferred stock in February 2008.
- Alleged damages: $650,000.
- Outcome: Written complaint received November 18, 2008; later settled on February 18, 2010 for $195,000. FINRA records note that Mr. Roggen did not contribute financially to the settlement and that, according to his statement, he was “found not to be negligent or responsible for any sales practice violations,” with the settlement reached through mediation at the claimants’ request.
Auction Rate Securities Liquidity Complaint
- Firm: UBS Financial Services Inc.
- Product type: Auction rate securities (ARS)
- Allegations: The client claimed he was misled regarding the liquidity and risk of ARS, alleging he had been told the investment had seven-day liquidity, was “FDIC insured,” and carried only the risk of not earning interest at times.
- Alleged damages: In excess of $5,000.
- Outcome: Written complaint received May 7, 2008 and later settled on December 23, 2008 for $100,000, pursuant to a global repurchase agreement UBS entered into with regulators to buy back ARS at par value. FINRA records note that the settlement was not based on any finding of wrongdoing by Mr. Roggen, and he did not contribute personally.
Government Debt Unsuitability Complaint (2005)
- Firm: UBS Financial Services Inc.
- Product type: Government debt security
- Allegations: Client alleged unsuitability in connection with government bond investments.
- Alleged damages: $52,000.
- Outcome: Complaint received April 17, 2005; matter settled on October 7, 2005 for $5,000 with no reported contribution by Mr. Roggen.
Additional Denied Lehman-Related Complaint
- Firm: UBS Financial Services Inc.
- Allegations: The client’s counsel alleged that Lehman preferred stock purchased between February 5, 2008 and June 23, 2009 was unsuitable and that the advisor told the client the investment was “sound,” backed by strong underwriting, would recover, and carried little risk.
- Alleged damages: $125,000.
- Outcome: Written complaint received June 23, 2009 and later denied by the firm on October 21, 2009 with no payment to the client.
Summary of Disclosures
In total, Mr. Roggen’s BrokerCheck report shows:
- 1 customer dispute resulting in an arbitration award/judgment for approximately $251,978.50
- 5 settled customer disputes, including multiple Lehman preferred stock and ARS cases
- 1 denied Lehman-related complaint with no action taken
- 1 pending 2025 complaint involving allegedly unsuitable private placement real estate investments
Investors should understand that some matters were settled without admissions of liability and that the pending complaint contains unproven allegations. However, the pattern and number of disputes—spanning unsuitable recommendations, misrepresentation, and liquidity-risk issues—may be significant when evaluating potential claims.
To obtain a copy of H. Todd Roggen’s FINRA BrokerCheck report, visit this link
Robert Wayne Pearce Is Committed to Recovering Your Investment Losses
FINRA Rule 2111 – Suitability in the Context of Roggen’s Alleged Misconduct
FINRA Rule 2111 (Suitability) requires a broker or associated person to have a reasonable basis to believe that any recommended transaction or investment strategy is suitable for the customer, based on the customer’s investment profile, including age, financial situation, investment objectives, risk tolerance, liquidity needs, and time horizon.
In the disputes involving Mr. Roggen, customers repeatedly alleged that he recommended unsuitable investments—particularly large positions in Lehman Brothers preferred stock and later private placement real estate securities—without adequately accounting for their risk, liquidity constraints, or fit with the customers’ stated goals.
If a FINRA arbitration panel finds that:
- a broker concentrated a customer’s assets in a single issuer or sector (e.g., Lehman preferred stock),
- recommended speculative private placements to investors who could not afford to lose the principal, or
- failed to adjust strategies when market conditions or client circumstances changed,
then those recommendations may be deemed unsuitable under Rule 2111, supporting an award of damages for the resulting losses.
FINRA Rule 2090 – Know Your Customer
FINRA Rule 2090 (Know Your Customer) requires member firms and their associated persons to use reasonable diligence, at account opening and on an ongoing basis, to know the essential facts concerning every customer and the authority of each person acting on the customer’s behalf.
In cases like those reported for Mr. Roggen, allegations that investments were unsuitable, overly risky, or misaligned with stated objectives often raise serious questions about whether the broker and firm:
- accurately documented the client’s risk tolerance, liquidity needs, and income requirements;
- updated customer information when circumstances changed; and
- ensured that complex products—such as auction rate securities and private placements—were appropriate for that particular investor.
If a broker fails to obtain and maintain accurate customer information, or ignores what is known about an investor’s financial situation when recommending speculative or illiquid products, arbitrators may find a violation of Rule 2090 alongside a Rule 2111 suitability breach.
FINRA Rule 2010 – Standards of Commercial Honor and Principles of Trade
FINRA Rule 2010 (Standards of Commercial Honor and Principles of Trade) requires that a member, “in the conduct of its business, shall observe high standards of commercial honor and just and equitable principles of trade.”
Rule 2010 serves as a broad “catch-all” ethics provision. Even when more specific rules—such as Rules 2111 and 2090—are not clearly established, a pattern of:
- misrepresenting or omitting material risks (e.g., promising that auction rate securities had cash-like liquidity or minimal risk),
- failing to disclose conflicts of interest or compensation tied to product sales, or
- ignoring repeated customer complaints about unsuitable strategies,
can be viewed as inconsistent with the high standards of commercial honor required by Rule 2010.
In Mr. Roggen’s case, the combination of an historical arbitration award, multiple settled disputes, and a new pending complaint alleging improper inducement into private placements may be cited by claimants as evidence that his conduct fell short of these ethical standards, even where the broker denies liability or where the firm paid settlements without admissions.
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.
