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The Law Offices of Robert Wayne Pearce, P.A. understands what is at stake in securities, commodities and investment law matters and constantly strives to secure the most favorable possible result. Mr. Pearce provides a complete review of your case and fully explains your legal options. The firm works to ensure that you have all of the information necessary to make a sound decision before any action is taken in your case.

For dedicated representation by a law firm with substantial experience in all kinds of securities, commodities and investment disputes, contact the firm by phone at 833-300-6983, toll free at 800-732-2889 or via e-mail. We may also be able to arrange a meeting with you at offices located in Boca Raton, Fort Lauderdale, Miami and West Palm Beach, Florida and elsewhere.

Nov 20, 2025

Raymond James Financial Services Broker Todd Roggen Under Investigation For Alleged Unsuitable Private Placement Investments FINRA Complaint

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: 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 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 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: Auction Rate Securities Liquidity Complaint Government Debt Unsuitability Complaint (2005) Additional Denied Lehman-Related Complaint Summary of Disclosures In total, Mr. Roggen’s BrokerCheck report shows: 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: 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: 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: 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.

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Nov 20, 2025

KKR Capital Markets LLC Broker Matthew Koelliker Under Investigation For Alleged Failure To Honor Limited Partnership Withdrawal Requests FINRA Complaint

Our firm is investigating KKR Capital Markets LLC broker and investment advisor Matthew Brett Koelliker (CRD# 5660722) of San Francisco, California, for potential investment-related misconduct involving private real estate direct investment limited partnership interests. According to public records from FINRA’s BrokerCheck system, investors have accused Koelliker of failing to honor withdrawal and redemption requests in a private real estate limited partnership, resulting in substantial alleged losses. Koelliker is currently registered as a General Securities Representative with KKR Capital Markets LLC and holds licenses in all 50 U.S. states, the District of Columbia, Puerto Rico, and the U.S. Virgin Islands. His BrokerCheck report discloses three customer disputes—one settled and two pending—tied to direct participation programs (DPPs), limited partnership (LP) interests, and real estate securities sold while he was associated with M360 Advisors, LLC. Financial Advisor’s Career History Matthew Brett Koelliker has spent his securities industry career focused on complex investment products and institutional asset management: In addition to his brokerage registrations, Koelliker has passed the Securities Industry Essentials (SIE), multiple Series 7 General Securities Representative examinations, the Series 3 National Commodity Futures Examination, and the Series 63 and Series 66 state securities law exams, reflecting qualifications to sell a wide range of securities and investment products nationwide. Matthew Brett Koelliker Fraud Allegations and Investor Complaints Explained FINRA’s BrokerCheck report for Matthew Brett Koelliker discloses three customer disputes tied to private real estate limited partnership interests categorized as Direct Investment – DPP & LP Interests and Real Estate Security products. All of the disputes stem from Koelliker’s activities while associated with M360 Advisors, LLC and concentrate on allegations that investors’ limited partnership interests were mismanaged, dropped sharply in value, and were not redeemed or withdrawn as promised under the fund’s governing documents. The allegations describe a recurring pattern: investors claim that they submitted withdrawal or redemption notices for their limited partnership interests, but the fund allegedly failed to honor those requests in full, even as the value of the investment purportedly declined significantly. These claims raise concerns about liquidity misrepresentations, suitability of illiquid private real estate offerings for the affected investors, and adherence to the limited partnership agreement. Below is a breakdown of the disclosed customer disputes: Summary of Customer Disputes As with all BrokerCheck disclosures, these matters consist of allegations that may be contested and have not necessarily been proven. The pending cases could be dismissed, resolved in Koelliker’s favor, or settled without any admission of wrongdoing. Nonetheless, the size of the claimed losses—particularly the eight-figure damages request in one pending civil action—and the pattern of disputes centered on the same type of illiquid real estate limited partnership highlight serious concerns for investors who purchased similar products through M360 Advisors or Koelliker. To obtain a copy of Matthew Brett Koelliker’s FINRA BrokerCheck report, visit this link. Robert Wayne Pearce Is Committed to Recovering Your Investment Losses One of the primary rules implicated by allegations of unsuitable or misrepresented private real estate limited partnership interests is FINRA Rule 2111, known as the Suitability rule. Rule 2111 requires a broker to have a reasonable basis to believe that any recommended security or investment strategy is suitable for at least some investors (reasonable-basis suitability) and suitable for each particular customer in light of that customer’s investment profile, including age, financial situation, risk tolerance, investment objectives, and liquidity needs. When a broker recommends an illiquid DPP or real estate limited partnership to investors who may need access to principal through redemptions or withdrawals, arbitrators will ask whether the broker adequately investigated the product’s risk, understood the liquidity restrictions and redemption provisions, and explained those risks to the client. The allegations against Koelliker—that investors saw a sudden decrease in value of their LP interests and that the fund allegedly failed to honor withdrawal and redemption requests in full—may be argued as violating Rule 2111’s customer-specific suitability obligations if arbitrators conclude the investments were inappropriate for the claimants’ risk tolerance and liquidity requirements. Another critical standard in these cases is FINRA Rule 2090, the Know Your Customer rule. Rule 2090 obligates member firms and their associated persons to use reasonable diligence to “know (and retain) the essential facts” concerning every customer, including information needed to service the account properly, follow special handling instructions, and comply with applicable laws and regulations. In disputes involving allegedly illiquid private real estate partnerships, arbitrators will consider whether the broker and firm adequately understood the customer’s income needs, time horizon, risk tolerance, and liquidity preferences before recommending or holding a concentrated position in a limited partnership that restricts withdrawals. If an investor reasonably expected to access funds in 2020 or 2021 based on the limited partnership agreement, but the fund purportedly refused or failed to honor those withdrawal notices, claimants may argue that the broker and firm breached their obligations under Rule 2090 by not fully appreciating and documenting the client’s liquidity needs and by failing to align the investment with those needs. Finally, many investor claims of this type invoke FINRA Rule 2010, which 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 functions as a broad ethical standard that can apply even when no more specific rule fully captures the misconduct. In the context of the allegations against Koelliker, investors may contend that failing to honor limited partnership withdrawal or redemption requests, not timely communicating about a sharp decline in the value of a real estate security, or placing investors into complex private offerings without fair, balanced, and complete disclosure falls below the “high standards of commercial honor” required by Rule 2010. Arbitrators often evaluate whether the advisor and firm acted in good faith, prioritized the customer’s interests, and adhered to the letter and spirit of the limited partnership agreement. If the evidence shows a pattern of disregard for investor instructions and contractual rights, Rule 2010 gives FINRA panels a basis to impose liability and sanctions even beyond technical suitability or KYC violations....

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Nov 20, 2025

Equitable Advisors LLC Financial Advisor Ryan Bartholomew Lacedonia Under Investigation For Alleged Misleading Investment Recommendations in FINRA Complaint

Our firm is investigating Equitable Advisors, LLC financial advisor and stockbroker Ryan Bartholomew Lacedonia (CRD# 5658696) of Tampa, Florida for potential investment-related misconduct arising from customer complaints alleging misleading investment information and losses in municipal bond funds and a managed money account. Financial Advisor’s Career History Ryan Bartholomew Lacedonia is currently registered with FINRA as both a general securities representative and an investment adviser representative with Equitable Advisors, LLC (CRD# 6627). He has been associated with Equitable Advisors since April 2022 and works out of a branch office in Tampa, Florida, while holding registrations in numerous U.S. states and territories. Mr. Lacedonia has spent his entire career in the securities industry. Before joining Equitable Advisors, he was dually registered with TIAA-CREF Individual & Institutional Services, LLC and Advice and Planning Services (CRD# 20472) in Tampa, Florida from approximately February 2015 through April 2022, where he served as a wealth management advisor and registered representative. His earlier experience includes working with ETRADE Securities LLC and ETRADE Capital Management, LLC (Tampa, Florida and Arlington, Virginia), as well as prior registrations with GAMCO Asset Management Inc., Gabelli & Company, Inc., Cohen & Steers Securities, LLC in New York, and an early stint with AXA Advisors, LLC in Miami, Florida dating back to 2009. In addition to his brokerage and advisory roles, Lacedonia has reported an outside business activity under the trade name PCG/Private Client Group, R.B Lace LLC in Tampa, where he is listed as owner. Ryan B. Lacedonia Fraud Allegations and Investor Complaints Explained According to his FINRA BrokerCheck report, Ryan Bartholomew Lacedonia has two customer dispute disclosures on his record. The disputes center on allegations that he provided misleading information to customers about the purchase of municipal bond funds and about the type of account and products for which a client qualified, resulting in claimed losses of tens of thousands of dollars. While one matter was settled by his former firm, another was closed with no action, and there has been no formal finding by FINRA that Lacedonia violated any rule in connection with these allegations. 2022 Municipal Bond Fund Misrepresentation Complaint – Settled In July 2022, a customer lodged a written complaint against Lacedonia’s former firm, TIAA-CREF Individual & Institutional Services, LLC. The client alleged that he was provided misleading information in 2021 concerning the purchase of two municipal bond funds and requested a refund of his losses, claiming damages of approximately $30,000. The firm reported that the complaint was resolved on August 3, 2022, through a monetary settlement of $22,637.47 paid to the customer. BrokerCheck indicates that Lacedonia did not personally contribute to the settlement. The product type in the disclosure is listed as “No Product,” but the narrative makes clear the dispute involved municipal bond funds and alleged misstatements or omissions about those investments. 2022 Managed Money Account Complaint – Closed With No Action In October 2022, another written complaint was filed with TIAA-CREF Individual & Institutional Services, LLC involving a former client who claimed he was misled by Lacedonia into believing that he qualified for the same employer-sponsored plan products his wife held. According to the disclosure, the customer alleged that instead of enrolling him in similar plan products, the representative invested his assets in a non-qualified managed money account. The client asserted that the managed money account had declined by approximately $35,000 and requested that all losses from inception be reimbursed and all fees refunded. The firm categorized the product type as “Other: Managed Money.” On November 9, 2022, the firm closed the complaint with “No Action,” indicating that no settlement or payment was made and no finding of wrongdoing was entered against Lacedonia in connection with this matter. Summary of Customer Dispute Disclosures As with all customer disputes reported in BrokerCheck, these disclosures reflect allegations only. An investor complaint, settlement, or closed-no-action entry does not by itself prove that the broker engaged in fraud, misrepresentation, or any violation of FINRA rules. In conclusion, the allegations involving Ryan Bartholomew Lacedonia underscore the types of issues that can arise when investors claim they were misled about the risks, features, or suitability of municipal bond funds or managed accounts, or about the nature of the retirement-plan products they were qualified to purchase. To obtain a copy of Ryan Bartholomew Lacedonia’s FINRA BrokerCheck report, visit this link. Robert Wayne Pearce Is Committed to Recovering Your Investment Losses FINRA Rule 2111 (Suitability) requires brokers and their firms to have a reasonable basis to believe that any recommended transaction or investment strategy is suitable for the customer based on that customer’s investment profile, including age, financial situation, objectives, risk tolerance, and liquidity needs. In the complaints involving Lacedonia, customers alleged that they received misleading information about municipal bond funds and were placed into a non-qualified managed money account instead of employer-sponsored plan products, which raises suitability questions about whether the investments and account structure were appropriate for their needs and expectations under Rule 2111. FINRA Rule 2210 (Communications with the Public) requires that broker-dealer communications be fair and balanced and prohibits false, exaggerated, unwarranted, or misleading statements. If a customer was led to believe that certain municipal bond funds or employer-sponsored plan products carried particular features, guarantees, or eligibility criteria that did not actually apply, regulators and arbitrators may view such statements as potentially misleading under Rule 2210, especially where account selection and product choice were driven by those communications. FINRA Rule 2010 (Standards of Commercial Honor and Principles of Trade) is a broad “catch-all” provision that requires members, in the conduct of their business, to observe high standards of commercial honor and just and equitable principles of trade. Even where a firm or advisor has not been formally charged, customer complaints alleging misrepresentation of investment products, mishandling of account types, or failure to correct misunderstandings can be evaluated under Rule 2010 to determine whether the conduct fell below the ethical and professional standards expected of FINRA-regulated professionals. For over 45 years, Robert Wayne Pearce has helped investors recover losses caused...

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Nov 20, 2025

LPL Financial Advisor David Nastri Under Investigation For Unsuitable Real Estate and Structured Product Investments FINRA Complaint

Our firm is investigating LPL Financial broker and investment adviser David Jon Nastri (CRD# 5178144) of Cheshire, Connecticut for potential investment-related misconduct involving allegedly unsuitable recommendations in real estate securities and structured products. Financial Advisor’s Career History According to FINRA BrokerCheck records, David Jon Nastri has been registered in the securities industry since 2006. Nastri is currently licensed in numerous U.S. states and territories through LPL, including Connecticut, Florida, New York, California, New Jersey, Massachusetts, and others, giving him a multi-state customer base. David J. Nastri Fraud Allegations and Investor Complaints Explained FINRA BrokerCheck discloses two customer dispute events in Nastri’s record, both involving allegations that complex investments were unsuitable and that significant risks were not properly disclosed. While these disputes involve serious allegations, investors should understand that some matters are contested and that settlements do not necessarily constitute an admission of wrongdoing by the broker or the firm. 2023–2025 FINRA Arbitration Over Real Estate Security Investment (Settled) Broker’s position: In a statement on BrokerCheck, Nastri denies any wrongdoing, asserts that the real estate investment’s features, benefits, liquidity restrictions, and risk of loss were explained and documented, and states that he believes LPL chose to settle the matter for a “nominal” amount well below the anticipated cost of a full arbitration hearing. 2020 Customer Complaint About Structured Product (Denied) Summary of Customer Disclosures These disputes highlight the types of complex, illiquid, or riskier products—such as real estate securities and structured products—that often give rise to FINRA arbitration claims when customers later experience unexpected losses or discover risks they believe were never properly explained. Conclusion The complaints involving David Jon Nastri focus on suitability and risk-disclosure issues in complex products. One customer arbitration involving a real estate security has already resulted in a $28,500 settlement, and a prior complaint regarding a structured product alleged that principal risk was not adequately disclosed. If you or a loved one invested in real estate securities, structured products, or other complex investments through David J. Nastri or another LPL Financial advisor and suffered losses, you may have potential claims that can be pursued through FINRA arbitration. To obtain a copy of David J. Nastri’s FINRA BrokerCheck report, visit this link Robert Wayne Pearce Is Committed to Recovering Your Investment Losses FINRA Rule 2111 – Suitability In disputes like those involving Mr. Nastri, FINRA Rule 2111 (Suitability) plays a central role. FINRA Rule 2111 requires a broker-dealer or associated person to have a reasonable basis to believe that any recommended transaction or investment strategy is suitable for the customer based on that customer’s investment profile—factors such as age, financial situation, investment experience, risk tolerance, time horizon, liquidity needs, and overall objectives. In the 2014 real estate security and the structured product complaint, investors alleged that the recommendations were inconsistent with their stated objectives and risk tolerance and that key risks, including the possibility of loss of principal and lack of liquidity, were not adequately disclosed. If a FINRA arbitration panel concludes that an advisor failed to understand a client’s profile or recommended complex products that exceeded the client’s risk tolerance, the panel may find a violation of Rule 2111 and award damages to the customer. FINRA Rule 2090 – Know Your Customer FINRA Rule 2090 (Know Your Customer) requires firms and their associated persons to use reasonable diligence at account opening and on an ongoing basis to know and retain the essential facts concerning every customer. Those essential facts include information necessary to effectively service the account, follow special handling instructions, understand who is authorized to act on the account, and comply with all applicable laws and rules. Where a customer alleges that the broker recommended a complex real estate security or structured product that did not match the client’s risk tolerance or financial situation, arbitrators often look to whether the firm and advisor complied with Rule 2090. If the broker failed to obtain or update critical information—such as the client’s need for capital preservation or inability to tolerate illiquidity—then both the firm and advisor may be exposed to liability for recommending investments that the customer was never an appropriate candidate to own. FINRA Rule 2010 – Standards of Commercial Honor and Principles of Trade Even when misconduct is not neatly captured by a specific rule, FINRA Rule 2010 (Standards of Commercial Honor and Principles of Trade) provides a broad ethical standard. Rule 2010 requires that “a member, in the conduct of its business, shall observe high standards of commercial honor and just and equitable principles of trade.” In the context of the allegations against David J. Nastri, a FINRA panel could view failure to fairly present the risks of complex, illiquid real estate and structured products, or a pattern of recommendations that appear to prioritize product sales over client interests, as conduct inconsistent with the high standards required by Rule 2010—even if the broker insists that documents were signed and some risks were mentioned. Rule 2010 often functions as a “catch-all” ethics rule, allowing arbitrators and regulators to sanction behavior that undermines investor trust or reflects poor professional judgment, even when no more specific rule is directly at issue. 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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Nov 20, 2025

LPL Financial Broker Shaun Floresca Under Investigation For Unsuitable Real Estate Investment Recommendations FINRA Complaint

Our firm is investigating LPL Financial broker and investment adviser Shaun B. Floresca (CRD# 4758697) of Chicago, Illinois for potential investment-related misconduct. Financial Advisor’s Career History Shaun B. Floresca has been registered in the securities industry since 2004. He is currently a General Securities Representative and investment adviser representative with LPL Financial LLC (CRD# 6413), working from a branch office at 11545 W. Touhy Ave., Chicago, Illinois, while the firm’s main office is in Fort Mill, South Carolina. Over the course of his career, Floresca has been registered with the following broker-dealers and investment advisory firms: In addition to his brokerage and advisory work, Floresca has reported other business activities, including working with a credit union investment program, insurance-related business through independent marketing organizations, and a small real-estate rental activity in Chicago. Shaun B. Floresca Fraud Allegations and Investor Complaints Explained According to FINRA’s BrokerCheck report, Shaun B. Floresca has been the subject of multiple customer disputes and a civil judgment/lien. The customer disputes center on recommendations of real estate securities made around 2014 that customers later alleged were inappropriate for their investment objectives and risk tolerance—classic allegations of unsuitable investments in alternative or illiquid products. Customer Dispute – FINRA Arbitration Case No. 23-00267 Floresca denies any wrongdoing and states that he provided “excellent, tailored service,” asserting that LPL elected to settle for business reasons and that he contributed no personal funds toward the settlement. Customer Dispute – FINRA Arbitration Case No. 24-00006 In his statement, Floresca again denies wrongdoing, asserts that risks, features, and liquidity restrictions of the recommended investments were fully discussed and documented through disclosure forms, and notes that he is not personally named in the arbitration but intends to assist LPL in defending the matter. Civil Judgment / Lien Disclosure While the judgment/lien disclosure is not directly related to investment recommendations, it may raise questions about financial responsibility and overall risk management practices. Summary of FINRA Disclosures for Shaun B. Floresca Investors who believe they lost money because of alternative or real estate securities recommended by Floresca—or any broker—should understand that real estate programs, non-traded REITs, and other complex products often involve higher fees, limited liquidity, and greater risk than traditional stocks and bonds. When such products are recommended to conservative or income-oriented investors without adequate risk disclosure, the recommendations may violate industry suitability and “know your customer” standards and expose the firm to liability in FINRA arbitration. To obtain a copy of Shaun B. Floresca’s FINRA BrokerCheck report, visit this link Robert Wayne Pearce Is Committed to Recovering Your Investment Losses FINRA Rule 2111 (Suitability) requires brokers to have a reasonable basis to believe that any recommended security or strategy is suitable for a customer based on that customer’s investment profile, including risk tolerance, time horizon, financial situation, and liquidity needs. In the Floresca disputes, customers alleged that a 2014 real estate investment did not fit their objectives or risk tolerance; arbitrators in such cases typically examine whether the broker performed adequate due diligence on the real estate product, explained its risks and illiquidity, and ensured the recommendation was not too risky or concentrated for the client’s profile. FINRA Rule 2090 (Know Your Customer) requires firms and their associated persons to use reasonable diligence to know the essential facts about every customer at account opening and on an ongoing basis, including financial status, investment experience, and objectives. When a customer later claims that an illiquid real estate security was inappropriate, arbitrators often ask whether the broker obtained and updated accurate information about the client’s income, net worth, risk tolerance, and need for liquidity and whether that information was considered before recommending the 2014 real estate investment at issue in the Floresca arbitrations. FINRA Rule 2010 (Standards of Commercial Honor and Principles of Trade) is a broad ethics rule requiring firms and brokers to observe high standards of commercial honor and just and equitable principles of trade in the conduct of their business. Even when specific suitability or “know your customer” violations are contested, regulators and arbitrators may look to Rule 2010 when brokers fail to treat customers fairly—for example, by recommending complex, high-commission real estate products to conservative investors without fully explaining the risks and liquidity constraints, or by failing to respond appropriately when clients raise concerns about performance or risk. 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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Nov 19, 2025

UBS Financial Services Advisor Sonia Attkiss Under Investigation For Options Overlay Unsuitability and Misrepresentation FINRA Complaints

Our firm is investigating UBS Financial Services broker and financial advisor Sonia Maria Attkiss (CRD# 2936806) of New York, New York and Westport, Connecticut for potential investment-related misconduct, including unsuitable options overlay recommendations, misrepresentation, and failure to follow client instructions. Financial Advisor’s Career History According to FINRA BrokerCheck, Sonia Maria Attkiss has worked in the securities industry since the late 1990s. She is currently registered as a General Securities Representative and investment adviser representative with UBS Financial Services Inc. (CRD# 8174), where she has been employed since November 20, 2015. She is registered in 53 U.S. states and territories and with 10 self-regulatory organizations, and works out of UBS offices at 299 Park Avenue in New York, New York and in Westport, Connecticut. Before joining UBS Financial Services Inc., Ms. Attkiss was registered with: In addition to her brokerage registrations, Ms. Attkiss has passed the Securities Industry Essentials (SIE), the Series 7 General Securities Representative Examination, and the Series 66 Uniform Combined State Law Examination. Sonia Maria Attkiss Fraud Allegations and Investor Complaints Explained FINRA BrokerCheck discloses multiple customer disputes involving Sonia Maria Attkiss, including an arbitration award and several settled options overlay cases. In total, six customer disputes are reported on her record, all relating to sales-practice allegations such as fraud, misrepresentation, unsuitability, failure to execute instructions, and other alleged violations. While some disputes were resolved through settlements without any individual contribution by Ms. Attkiss and without admissions of wrongdoing, the volume and nature of these disclosures raise serious questions about the suitability of certain recommendations and the handling of customer accounts, particularly involving an options overlay strategy implemented in a wrap-fee program. 1. Options Overlay Strategy Arbitration – Alleged Fraud, Misrepresentation, and Unsuitability One customer dispute culminated in a FINRA arbitration award against UBS Financial Services Inc. (Case No. 20-00941). In that matter, customers alleged that Ms. Attkiss and her member firm engaged in: The dispute centered on options investments, with customers claiming more than $730,631.25 in damages. A FINRA arbitration panel later ordered UBS Financial Services Inc. to pay the claimants $40,000.00 in compensatory damages plus $300.00 in reimbursement of non-refundable filing fees. From the broker-reported version of the same case, the timeframe of the disputed activity was 2017–2019, and the product involved was an in-house options overlay strategy offered within a wrap-fee program. The complaint alleged unsuitability and misrepresentation, claimed damages of $500,000, and ultimately settled for $40,300.00, with no individual contribution reported by Ms. Attkiss. Bullet-point summary of this disclosure: 2. 2025 Equity Complaint – Alleged Failure to Execute Trades as Instructed BrokerCheck also reports a 2025 customer complaint involving alleged failures to execute equity trades as instructed. According to UBS’s disclosure, the client alleged that Ms. Attkiss “did not execute trades as instructed” between March 26, 2025 and June 18, 2025 in a listed equity account. The firm coded the complaint as oral only (no written component), with no specific dollar amount claimed in the initial damages field. The matter was later marked as “settled” on August 18, 2025 for $46,733.93, with no individual contribution reported by Ms. Attkiss. Bullet-point summary of this disclosure: This type of allegation often overlaps with issues described as unauthorized trading or failure to follow client instructions, which can form the basis of a claim for recovery in a FINRA arbitration. Investors who experience similar issues may benefit from consulting a lawyer familiar with unauthorized trading and related misconduct claims. 3. Multiple Options Overlay Settlements (2016–2024) In addition to the arbitration award case, BrokerCheck lists three settled FINRA arbitrations and one additional settled customer complaint involving an in-house options overlay strategy that was recommended and held between 2016 and April 2023. Across these disclosures, customers alleged that Ms. Attkiss and UBS Financial Services Inc. recommended an options overlay strategy that was unsuitable and misrepresented, exposing clients to inappropriate risk. The reported timeframes and settlement amounts include: Bullet-point summary of these options overlay disclosures: Claims involving complex strategies such as options overlays frequently raise suitability concerns when the strategy does not match a client’s risk tolerance, investment objectives, or capacity to sustain losses, and they may give rise to unsuitable investment claims. Investors who suffered losses in such strategies may have potential claims for recovery through FINRA arbitration and unsuitable investment actions. BrokerCheck reports one additional options overlay-related arbitration filed in July 2020 (FINRA Case No. 20-02109) alleging unsuitability and misrepresentation starting in 2016, with claimed damages between $500,000 and $1,000,000. That matter was ultimately resolved with an arbitration award in favor of respondents/defendants and was closed with no payment to the customer. Bullet-point summary of this disclosure: To obtain a copy of Sonia Maria Attkiss’s FINRA BrokerCheck report, visit this link Robert Wayne Pearce Is Committed to Recovering Your Investment Losses In the context of the options overlay complaints, FINRA Rule 2111 (Suitability) requires that a broker have a reasonable basis to believe that any recommended security or investment strategy is suitable for the customer based on that customer’s investment profile, including age, financial situation, risk tolerance, investment objectives, and liquidity needs. When an advisor recommends a leveraged, options-based overlay strategy inside a wrap-fee account, Rule 2111 expects the broker to understand the product’s risks and to match those risks to clients who are truly able and willing to bear them. If a broker steers conservative or income-oriented investors into a complex, volatility-dependent options overlay without adequately evaluating their risk tolerance or explaining the potential downside, arbitrators can conclude that the recommendations violated the customer-specific suitability and reasonable-basis suitability components of Rule 2111. In the disputes involving Ms. Attkiss, repeated allegations that the options overlay was unsuitable for various clients suggest that arbitrators and regulators may closely examine whether her recommendations met these suitability obligations. In addition, FINRA Rule 2010 (Standards of Commercial Honor and Just and Equitable Principles of Trade) functions as a broad ethical rule that requires members and their associated persons to conduct business with high standards of commercial honor and just and equitable principles of...

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Nov 19, 2025

Aegis Capital Corp. Broker Matthew Winthrop Under Investigation For Alleged Excessive Trading and Unauthorized Transactions FINRA Complaint

Our firm is investigating Aegis Capital Corp. broker and investment adviser representative Matthew Winthrop (CRD# 2445102) of Melville, New York, for potential investment-related misconduct, including a history of customer disputes and a recent termination after allegations of excessive trading in client brokerage accounts. Financial Advisor’s Career History According to his FINRA BrokerCheck report, Matthew Winthrop has worked in the securities industry for more than three decades with multiple national brokerage firms. He is currently registered as a general securities representative and principal with Aegis Capital Corp. (CRD# 15007), based out of its Melville, New York branch office at 1305 Walt Whitman Road, Suite 120, and is also registered through Aegis in several states, including Connecticut, Florida, New York, Pennsylvania, Texas, and Virginia. Mr. Winthrop’s registration and employment history reported to FINRA includes: Over the course of this career, Mr. Winthrop has taken and passed several securities industry qualification examinations, including the Series 7 (General Securities Representative), Series 24 (General Securities Principal), Series 31, Series 63, and Series 66. Matthew Winthrop Fraud Allegations and Investor Complaints Explained FINRA BrokerCheck for Matthew Winthrop discloses five customer disputes and one employment separation after allegations. One of the customer disputes resulted in a monetary settlement of $50,000 paid by a prior firm; the remaining disputes were denied or closed with no action. In 2025, Equitable Advisors disclosed that it discharged Mr. Winthrop for alleged excessive trading in client brokerage accounts. Below is a breakdown of the disclosed matters as reported on BrokerCheck. Investors should understand that many of these items involve contested allegations that may not have been fully adjudicated, and some were denied or closed without payment to the customer. 2015 Oppenheimer IRA Distribution & Unauthorized Trade Lawsuit – $50,000 Settlement In 2015, a customer filed a federal court complaint against Oppenheimer & Co. Inc. relating to an IRA transaction and alleged unauthorized trading while Mr. Winthrop was associated with the firm. In his BrokerCheck “Broker Statement,” Mr. Winthrop states that the complaint related to a premature IRA distribution he maintains was coded correctly by the firm and that he was never named personally as a defendant in the litigation. 2003 UBS PaineWebber Unauthorized Trading, Excessive Trading, and Unsuitable Investment Complaint – Denied In 2003, a UBS PaineWebber customer alleged that Mr. Winthrop made trades in her account without permission, excessively traded the account, and placed her in unsuitable investments. Mr. Winthrop’s response denies all allegations, asserting that all transactions were done with prior customer authorization, were consistent with her investment objectives, and that the complaint stemmed from market performance rather than misconduct. 2002 Prudential (PSI) Risk Misrepresentation Complaint – Denied In 2002, while at Prudential Securities (PSI), a customer alleged that his financial advisor misrepresented investments and their risks over a five-year period. Mr. Winthrop’s statement notes that he had not spoken to the customer since 1998 and that the client did not follow him to his new firm, leaving him “at a loss” as to why he was named in the complaint. 1999 Prudential Unauthorized Stock Purchase Complaint – Denied A 1999 complaint at Prudential Securities alleged that stocks were purchased in a customer’s account without her knowledge, resulting in claimed losses of $21,777. 1998 Prudential Excessive & Speculative Trading Complaint – Closed With No Action In 1998, another Prudential customer complaint alleged that Mr. Winthrop engaged in excessive and speculative trading with poor asset allocation, claiming damages greater than $55,834. The broker’s statement adds that the item was more than 24 months old and therefore “no longer reportable” for certain regulatory purposes. 2025 Equitable Advisors Termination After Allegations of Excessive Trading The most recent disclosure on Mr. Winthrop’s BrokerCheck record involves his September 15, 2025 discharge from Equitable Advisors, LLC. The firm reported that it terminated him for: Mr. Winthrop’s own version of the termination disclosure essentially repeats Equitable’s description, indicating that the firm alleged excessive trading in client accounts tied to equity securities. Summary of Disclosed Events As of the most recent BrokerCheck report, the disclosed events for Matthew Winthrop include: Investors should note that a settled claim does not necessarily mean an admission of wrongdoing, and denied or closed complaints may reflect contested allegations that could not be substantiated—or that firms resolved without payment for business reasons. However, regulators and arbitrators often consider the pattern of complaints, not just the outcome of any single case, when evaluating potential broker misconduct. To obtain a copy of Matthew Winthrop’s FINRA BrokerCheck report, visit this link Robert Wayne Pearce Is Committed to Recovering Your Investment Losses Nationwide Representation in FINRA Arbitration The Law Offices of Robert Wayne Pearce, P.A., is a nationally recognized investment fraud lawyer firm that represents investors in securities arbitration, litigation, and mediation across the country, including claims involving excessive trading, unauthorized transactions, and unsuitable recommendations. Attorney Pearce and his team regularly represent investors in FINRA arbitration proceedings, handling claims against many of the largest Wall Street firms. If you believe your broker engaged in misconduct similar to the allegations involving Matthew Winthrop—such as unauthorized trades, excessive turnover in your account, or misleading explanations of risk—you may have a viable claim to recover your losses. Experience Litigating Churning and Excessive Trading Claims Allegations of “excessive trading” in client accounts are commonly referred to as churning, a practice where brokers generate unnecessary trades primarily to increase commissions. Our firm has extensive experience pursuing churning and excessive trading cases on behalf of investors whose accounts were over-traded. We regularly analyze turnover rates, cost-to-equity ratios, and patterns of in-and-out trading to show how broker activity violated industry rules and customer best interests. If your portfolio shows unusually high trading frequency, increasing losses, and mounting commissions, our churning and excessive trading team can help you determine whether your broker’s conduct was improper and whether you can seek compensation. Florida-Based Securities Fraud Firm Serving Investors Nationwide From its Florida headquarters, The Law Offices of Robert Wayne Pearce, P.A. routinely represents investors throughout the United States who have suffered from churning, unsuitable investments, unauthorized...

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Nov 19, 2025

B. Riley Wealth Management Broker Jack Bruscianelli Under Investigation For Unsuitable Investment Recommendations and Sales Practice Violations FINRA Complaint

Jack F. Bruscianelli (CRD# 2113986) is a longtime stockbroker and general securities principal currently registered with B. Riley Wealth Management in Oakbrook Terrace, Illinois, and our firm is investigating allegations that he recommended unsuitable investments and engaged in other sales practice violations that led to significant investor losses. Stockbroker’s Career History According to FINRA BrokerCheck, Jack F. Bruscianelli has been in the securities industry since 1991 and is currently approved as both a General Securities Representative and General Securities Principal with B. Riley Wealth Management (CRD# 2543). He is licensed in approximately 20 U.S. states and territories, including Illinois, Florida, New York, California, and Texas. His current registrations and branch offices include: Bruscianelli’s prior registrations include a long tenure at National Securities Corporation and several other firms: In addition to his brokerage work, Bruscianelli has reported outside business activities, including a non-investment-related real estate company (Brumar) in Woodridge, Illinois, and an investment-related DBA, JBT Wealth Management, for securities business conducted through B. Riley Wealth Management. Jack F. Bruscianelli Fraud Allegations and Investor Complaints Explained FINRA BrokerCheck for Jack F. Bruscianelli discloses one regulatory event and five customer disputes, including a pending FINRA arbitration filed in 2025 alleging unsuitable recommendations in individual stocks and an exchange-traded fund. Below is a breakdown of the reported regulatory matter and customer complaints. Regulatory Action – Indiana Securities Department In 1999, the Indiana Securities Department initiated a regulatory action against Bruscianelli related to his disciplinary history: This regulatory event indicates that Indiana imposed special conditions on his registration due to prior concerns about his record, even though the action did not focus on a specific transaction or security. Customer Disputes – Private Placements, OTC Stocks, and Account Activity Bruscianelli’s BrokerCheck report shows multiple investor complaints and arbitrations alleging unsuitability, securities fraud, excessive trading, misrepresentation, and other sales practice violations. Key reported events include: Summary of Disclosure Events For context, Bruscianelli’s BrokerCheck matrix lists the following disclosure counts: These disclosures indicate a pattern of claims involving unsuitable trading, misrepresentation or omissions, and breach of fiduciary duty, particularly in OTC stocks and unsuitable investment recommendations that allegedly led to investor losses. Investors who worked with Jack F. Bruscianelli and believe they suffered losses in OTC equities, private placements, mutual funds, or ETFs should carefully review their account statements and trade confirmations. In many cases, alleged misconduct of this kind can be actionable in FINRA arbitration or other forums that allow investors to pursue recovery of their losses. To obtain a copy of Jack F. Bruscianelli’s FINRA BrokerCheck report, visit this link. Robert Wayne Pearce Is Committed to Recovering Your Investment Losses In disputes like those involving private placements, OTC equities, and concentrated positions in volatile ETFs, one of the most important rules arbitrators look at is FINRA Rule 2111 (Suitability). This rule requires that a broker have a reasonable basis to believe that any recommended transaction or investment strategy is suitable for the customer based on that customer’s investment profile, including factors such as age, financial situation, investment objectives, risk tolerance, time horizon, and liquidity needs. In the 2017 private placement case and the 2025 pending arbitration involving Movano, Inc. and the iShares Russian ETF, the core allegation is that Bruscianelli and his firm made unsuitable recommendations. If the investments were high-risk, illiquid, overly concentrated, or inconsistent with the client’s stated objectives, arbitrators may find that such recommendations violated Rule 2111’s customer-specific suitability obligations. A pattern of repeated trades or concentration in a narrow range of speculative securities may also implicate the “quantitative suitability” component of Rule 2111, which prohibits excessive trading that renders the account’s overall strategy unsuitable when viewed as a whole. Another central standard in these types of cases is FINRA Rule 2010, which requires brokers and firms to “observe high standards of commercial honor and just and equitable principles of trade.” Rule 2010 functions as a broad ethical “catch-all” provision. Even when conduct might not fit neatly into a specific suitability or disclosure rule, arbitrators and regulators can use Rule 2010 to address unethical or unfair practices. In the context of the disclosures on Bruscianelli’s record, allegations of: may all be analyzed under Rule 2010. When a broker oversells the safety of complex or speculative products, fails to provide full and fair disclosure, or continues trading in a way that benefits commissions more than the customer’s interests, those actions can be characterized as a failure to uphold “high standards of commercial honor and just and equitable principles of trade,” even if no criminal or regulatory charges are brought. Because one of Bruscianelli’s early cases involved allegations against him as a branch office manager, another important rule in these circumstances is FINRA Rule 3110 (Supervision). Rule 3110 requires brokerage firms to establish, maintain, and enforce a supervisory system reasonably designed to ensure compliance with securities laws and FINRA rules, including written supervisory procedures and effective oversight of branch offices and associated persons. In the H.J. Meyers arbitration, investors alleged excessive and unsuitable trading, misleading statements, and other violations while Bruscianelli acted as branch office manager. Claims like these can raise questions about whether supervisory obligations were fulfilled—both by the firm and by the supervising principal. Under Rule 3110, firms must reasonably monitor: Where a branch manager is directly named in a complaint, arbitrators may consider whether he or she properly implemented supervisory procedures, responded to red flags, or allowed problematic sales practices to continue. A failure to supervise can expose firms and supervising principals to liability, especially when a pattern of unsuitability, misrepresentation, or excessive trading is alleged across multiple customer accounts. 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., is a nationally recognized investment fraud lawyer practice that represents clients nationwide on a no-recovery, no-fee basis through FINRA arbitration and related proceedings.

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Nov 19, 2025

Global Financial Services Broker Eduardo Leon Jr. Under Investigation For Unsuitable Volatility-Linked ETN and Foreign Currency Bond Recommendations FINRA Complaint

Our firm is investigating Global Financial Services broker and registered account representative Eduardo Leon Jr (CRD# 2232647) of Houston, Texas for potential investment-related misconduct, including allegedly unsuitable recommendations in volatility-linked exchange-traded notes and concentrated positions in non-U.S. corporate bonds that have drawn a FINRA regulatory action and multiple six-figure customer complaints. Financial Advisor’s Career History Eduardo Leon Jr has spent his entire securities career in the brokerage industry. Since July 1994, he has been registered with Global Financial Services, L.L.C. (CRD# 35699), working out of the firm’s branch office at 1330 Post Oak Blvd., Suite 2100, in Houston, Texas. He is approved as a General Securities Principal, General Securities Representative, and Securities Trader and is licensed in Colorado, New York, and Texas. Before joining Global Financial Services, Leon was previously registered with: Eduardo Leon Jr Fraud Allegations and Investor Complaints Explained Public FINRA BrokerCheck records show that Eduardo Leon Jr has been the subject of one FINRA regulatory action and four customer disputes, several involving non-U.S. corporate bonds, alleged over-concentration, and questions about whether the investments were in line with clients’ risk profiles and instructions. FINRA Regulatory Action – Reg BI and Unsuitable Recommendations In May 2025, FINRA initiated a regulatory action (Docket No. 2022074734102) against Leon arising from his recommendations to both retail and non-retail customers at Global Financial Services. According to the Acceptance, Waiver & Consent (AWC), FINRA alleged that: Without admitting or denying FINRA’s findings, Leon consented to: FINRA classifies this matter as a final regulatory action based on violations of Reg BI’s best-interest standard for broker-dealer recommendations. 2023 FINRA Arbitration – Alleged Negligent Over-Purchase of Non-U.S. Corporate Bond In March 2023, a client filed a FINRA arbitration in Boca Raton, Florida against Global Financial Services and Leon. Key allegations included: The client sought $198,040 in damages. The case was settled in April 2023 for $174,175, all of which was reported as paid by Leon personally. 2022 Customer Complaint – Short-Duration B+ Bond and Moderate Risk Tolerance In March 2022, another customer lodged a written complaint involving a short-duration corporate bond that defaulted shortly after purchase. According to the disclosure: The customer claimed $321,179.80 in damages. The matter was settled in September 2022 for $265,943, again reported entirely as Leon’s individual contribution. 2022 Customer Complaint – Short-Duration Bond and Failure to Honor Stop-Loss Instructions A separate written complaint, also received in March 2022, involved similar alleged conduct and additional stop-loss issues. The disclosure describes that: The client sought $428,771.30 in damages. The case was settled in September 2022 for $235,000, all attributed to Leon’s individual contribution. 2008 FINRA Arbitration – Equity and Options Sales-Practice Violations In 2008, customers whose accounts were opened in 2002 filed a FINRA arbitration alleging sales-practice violations in 2007–2008 relating to equities and options. The disclosure notes that: The broker statement explains that the firm settled to avoid the additional legal expense of a hearing, with $50,000 paid by the broker who handled the accounts, who was later terminated. Leon reported no personal contribution to that settlement. Summary of Disclosures Based on the current BrokerCheck report, Leon’s record includes: While some events have been settled and the regulatory matter resolved through an AWC, investors should understand that settlements and FINRA sanctions do not automatically make them whole. Many customers with similar fact patterns may still have viable FINRA arbitration claims to recover investment losses stemming from unsuitable investments, over-concentration, failure to follow instructions, or other forms of broker misconduct. To obtain a copy of Eduardo Leon Jr.’s FINRA BrokerCheck report, visit this link. Robert Wayne Pearce Is Committed to Recovering Your Investment Losses FINRA Rule 2111 (Suitability) and Concentrated Corporate Bond Positions FINRA Rule 2111 (Suitability) requires that a broker have a reasonable basis to believe that any recommended transaction or investment strategy is suitable for the customer based on that customer’s investment profile, including age, financial situation, tax status, investment objectives, risk tolerance, time horizon, liquidity needs, and experience. Rule 2111 imposes three main suitability obligations: In the complaints involving Leon, customers alleged that he: When a broker builds concentrated positions in lower-rated bonds, or executes trades without adequate communication and risk discussion, arbitrators may find that: Investors who suffered losses in these kinds of trades may be able to pursue claims alleging violations of Rule 2111, even where there is no separate Reg BI finding. FINRA Rule 2010 (Standards of Commercial Honor and Principles of Trade) FINRA Rule 2010 requires that members and their associated persons “observe high standards of commercial honor and just and equitable principles of trade” in the conduct of their business. Rule 2010 is often described as a “catch-all” ethics rule that can apply whenever a broker’s conduct falls short of fair dealing, even if no other specific rule neatly applies. Allegations of: can all support a Rule 2010 claim when they demonstrate a departure from the high standards of commercial honor expected in the industry. In the disclosures concerning Leon, customers alleged that he: Arbitrators may view such conduct—if proven—as inconsistent with Rule 2010’s requirement of ethical treatment and fair dealing, particularly where customers repeatedly allege that they were not adequately informed or that their explicit instructions were not followed. 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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Nov 19, 2025

Ceros Financial Services Broker Thomas Anthony Kieffer Under Investigation For Breach of Duty and Unsuitable Investments FINRA Complaint

Our firm is investigating former Ceros Financial Services broker and financial planner Thomas Anthony Kieffer (CRD# 269086) of Chesterfield, Missouri, concerning customer complaints involving managed stock portfolios, alleged breach of duty, negligence, and unsuitable investment recommendations. Stockbroker’s Career History According to his FINRA BrokerCheck report, Thomas Anthony Kieffer entered the securities industry in 1971 and is currently not registered as a broker with any FINRA member firm. He has spent much of his career associated with firms in Arizona and Missouri while operating an investment-related business in Chesterfield, Missouri. From approximately January 2010 until February 2022, Kieffer was registered as a broker with Ceros Financial Services, Inc. (CRD# 37869) in Chesterfield, Missouri. Before joining Ceros, he was registered with Girard Securities, Inc. (CRD# 18697) in Chesterfield from September 2002 through December 2009. Prior to that, he spent roughly fourteen years with Spelman & Co., Inc. (CRD# 10232) in Phoenix, Arizona, from August 1988 to September 2002. Earlier in his career, Kieffer was associated with First Affiliated Securities, Inc. (CRD# 6871) from May 1980 to August 1988, FSC Securities Corporation (CRD# 7461) from November 1978 to June 1980, and both MONY Sales, Inc. (CRD# 4386) and The Mutual Life Insurance Company of New York (CRD# 2873) from June 1971 to October 1977. In addition to his brokerage registrations, Kieffer has reported serving since February 1977 as President and a 33.3% owner of St. Louis Financial Planners Inc. in Chesterfield, Missouri, an investment-related business where he has engaged in advisory and planning activity for clients. Thomas Anthony Kieffer Fraud Allegations and Investor Complaints Explained BrokerCheck for Thomas Anthony Kieffer discloses three customer disputes, all categorized as Customer Dispute – Settled, arising from his work with St. Louis Financial Planners, Inc. involving managed individual stock portfolios. Collectively, customers alleged more than $1.22 million in damages, and the disputes were resolved through settlements totaling more than $662,000, much of which was personally contributed by Kieffer. These complaints highlight allegations of breach of duty, negligence, and unsuitable investments in managed stock portfolios—issues that often appear in FINRA arbitration claims when investors believe their advisors failed to manage risk appropriately or to tailor recommendations to their financial situation and objectives. Key Customer Disputes Reported on Kieffer’s Record Summary of Disclosure History Investors should understand that, as with all BrokerCheck disclosures, these events are reported by firms, the broker, and/or regulators, and settlements typically occur without an admission of liability. However, the pattern of multiple disputes involving similar allegations in managed portfolios over several years may be a red flag for potential mismanagement of investment accounts and failure to align recommendations with clients’ risk tolerance and objectives. In light of these settlements and the serious nature of the allegations, current and former customers of Thomas Anthony Kieffer or St. Louis Financial Planners, Inc. who experienced significant losses in managed stock portfolios should consider whether they may have FINRA arbitration claims for negligence and breach of fiduciary duty or unsuitable investment strategies. To obtain a copy of Thomas Anthony Kieffer’s FINRA BrokerCheck report, visit this link. Robert Wayne Pearce Is Committed to Recovering Your Investment Losses FINRA Rule 2111 (Suitability) requires a broker to have a reasonable basis to believe that any recommended transaction or investment strategy is suitable for the customer based on that individual’s investment profile, including age, financial situation, risk tolerance, time horizon, and liquidity needs. When a customer alleges that a managed stock portfolio was unsuitable, too risky, or inconsistent with stated objectives, arbitrators ask whether the broker performed adequate due diligence on the securities and strategy and whether the portfolio was appropriately diversified and aligned with the client’s risk tolerance. In the disputes involving Thomas Kieffer, the allegations of unsuitable investments and large losses in managed individual stock portfolios suggest that claimants may have argued that the portfolio construction and ongoing management violated Rule 2111’s customer-specific suitability obligations. Section 6. 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 and retain the essential facts concerning every customer and the authority of each person acting on the customer’s behalf. Essential facts include information needed to service the account properly, follow special handling instructions, and comply with applicable laws and rules. In the context of the Kieffer complaints, investors may argue that if their accounts were concentrated in volatile stocks or managed with a risk profile inconsistent with their age, financial situation, or stated objectives, then the broker failed to properly “know the customer” and update his understanding of their needs, thereby contributing to the alleged breach of duty and negligent management of their portfolios. Section 7. FINRA Rule 2010 – Standards of Commercial Honor and Principles of Trade FINRA Rule 2010 (Standards of Commercial Honor and Principles of Trade) is a broad ethics rule requiring that, in the conduct of their business, members and associated persons observe high standards of commercial honor and just and equitable principles of trade. Even where a particular transaction does not fit neatly into a technical suitability or know-your-customer violation, patterns of conduct involving repeated breach of duty, negligent portfolio management, or failure to act in a client’s best interests can still be charged under Rule 2010. The multiple managed account disputes disclosed on Kieffer’s record—and the substantial settlements paid to customers—could be cited by investors as evidence that his conduct fell below the high ethical standards required by Rule 2010, especially if arbitrators find that he failed to manage risk, follow client objectives, or respond appropriately to market conditions in those accounts. 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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