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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.

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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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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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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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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Moloney Securities Co., Inc. CEO and Financial Advisor Donald Hancock Under Investigation For Regulation Best Interest Violations and Unsuitable GWG L Bond and Alternative Investment Recommendations, FINRA Complaint

Our firm is investigating Moloney Securities Co., Inc. CEO and financial advisor Donald Ralph Hancock (CRD# 828811) of Manchester, Missouri for potential Regulation Best Interest and suitability-related misconduct involving high-risk GWG L Bonds and other alternative investments recommended to retail investors. Financial Advisor’s Career History Donald R. Hancock (CRD# 828811) has been in the securities industry since 1976 and is currently registered with Moloney Securities Co., Inc. and Moloney Securities Asset Management LLC in Manchester, Missouri, where he serves in senior leadership roles including Chief Executive Officer and financial officer. His prior registrations include tenures with R. Rowland & Co., Inc., A.G. Edwards & Sons, Inc., D.R. Hancock & Company, Inc., Hancock Securities Group, LLC, Hancock Investment Advisors, LLC, and Moloney Investment Advisory LLC. Over his nearly five-decade career, Hancock has held multiple principal and supervisory licenses, including General Securities Principal, Municipal Securities Principal, Financial and Operations Principal, Registered Options Principal, Investment Banking Principal, and Securities Trader Principal, along with state registrations in more than 30 U.S. jurisdictions. Donald R. Hancock Fraud Allegations and Investor Complaints Explained According to Hancock’s FINRA BrokerCheck report, his record includes two regulatory events and two customer disputes, all of which center on supervisory, continuing-education, and Reg BI care-obligation issues, as well as allegations of unsuitable recommendations in high-risk debt and alternative investments such as GWG L Bonds, oil and gas programs, direct participation programs (DPPs), and real estate securities. 2024 SEC Regulation Best Interest Order Over GWG L Bonds On September 27, 2024, the U.S. Securities and Exchange Commission instituted public administrative and cease-and-desist proceedings against Moloney Securities Co., Inc., Hancock, and two other representatives involving recommendations of GWG Holdings, Inc. “L Bonds” between June 30, 2020 (the Regulation Best Interest compliance date) and approximately January 15, 2022. The SEC alleged that: The SEC order is final and, as to Hancock, imposes the following monetary sanctions: For a total individual monetary obligation of $58,341, which the order indicates must be paid and distributed to investors through a Fair Fund. Hancock agreed to the order on a “neither admit nor deny” basis but was found to have willfully violated the General Obligation of Regulation Best Interest (Exchange Act Rule 15l-1(a)(1)). 2000 NASD Supervisory and Continuing-Education Violations Hancock’s record also shows a prior regulatory matter from 2000 with NASD Regulation, Inc. (a predecessor to FINRA). In that case, NASD alleged that: Without admitting or denying the findings, Hancock and the firm entered into an Acceptance, Waiver & Consent (AWC) and were jointly and severally fined $5,000, which was later paid in full. The matter is final. Recent FINRA Customer Dispute Settlements In addition to the regulatory events, Hancock has two recent customer disputes that were resolved through FINRA arbitration: Summary of Disclosures (Action and Disposition) Investors should understand that some of these matters were resolved by negotiated settlement, often on a “neither admit nor deny” basis, and Hancock continues to refute the customer allegations despite the payments made to claimants. Based on these disclosures, investors who purchased GWG L Bonds, high-risk corporate debt, or alternative investments such as oil and gas programs and real estate securities through Hancock and Moloney Securities may have potential claims for recovery of their losses in FINRA arbitration or other forums. To obtain a copy of Donald R. Hancock’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 a specific recommendation is suitable for a particular customer, based on that customer’s investment profile (age, financial situation, tax status, investment objectives, risk tolerance, and other holdings). The customer disputes on Hancock’s record allege suitability and negligence in connection with portfolios heavily concentrated in corporate debt and alternative investments such as oil and gas programs, DPPs, and real estate securities. When a broker loads an investor’s account with complex or illiquid products that are inconsistent with the investor’s risk tolerance, liquidity needs, or time horizon, arbitrators often view that pattern as evidence of a violation of Rule 2111 and related common-law duties of care and loyalty—even if the broker denies wrongdoing and the firm settles “for business reasons.” FINRA Rule 3110 (Supervision) and FINRA Rule 2010 (Standards of Commercial Honor and Principles of Trade), together with their NASD predecessors (Rules 3010 and 2110), require firms and supervisors to establish and enforce a supervisory system reasonably designed to achieve compliance with securities laws and FINRA rules. The 2000 NASD action against Hancock, which cited failures to maintain written supervisory procedures and to prevent unregistered representatives from acting as general securities reps, illustrates how supervisory lapses can expose firms and principals to regulatory sanctions. In combination with the SEC’s later findings about Moloney’s inadequate Reg BI policies and conflicts-of-interest controls, these rules underscore that investors may have claims not only against individual brokers but also against the supervisory and firm-level structures that allowed unsuitable or non-compliant sales practices to occur. 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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Realta Equities and Realta Investment Advisors Broker Ashley Romiti Under Investigation For Unsuitable DST and Real Estate Securities Recommendations FINRA Complaint

Ashley Quinn Romiti (CRD# 7636987). Our firm is investigating Realta Equities, Inc. broker and Realta Investment Advisors, Inc. investment adviser representative Ashley Quinn Romiti of San Juan Capistrano, California for potential investment-related misconduct involving allegedly unsuitable recommendations in Delaware Statutory Trust (DST) and other real estate securities. Financial Advisor’s Career History According to her FINRA BrokerCheck report, Ashley Quinn Romiti is currently registered as a General Securities Representative with Realta Equities, Inc. and as an investment adviser representative with Realta Investment Advisors, Inc. She has been registered with both firms since March 3, 2025, working primarily out of San Juan Capistrano, California, while also listing a Wilmington, Delaware office address. Romiti has passed the Securities Industry Essentials (SIE) exam, the Series 7TO General Securities Representative Examination, and the Series 66 Uniform Combined State Law Examination. She is licensed in all 50 U.S. states, the District of Columbia, and Puerto Rico. Before joining Realta Equities and Realta Investment Advisors, Romiti was registered with Arkadios Capital (broker) and Arkadios Wealth Advisors (investment adviser) from July/August 2023 through March 2025. Prior to that, she was associated with Emerson Equity LLC as both a broker and investment adviser from November 2022 through November 2023, based in Irvine and San Mateo, California. Her employment history also includes investment-related business development roles at Perch Wealth, Verada, and Topside Real Estate, as well as non-investment-related positions in business development and case management. Ashley Quinn Romiti Fraud Allegations and Investor Complaints Explained Romiti’s BrokerCheck report discloses two pending customer dispute events, both arising from the same FINRA arbitration proceeding filed in October 2025. The disclosures describe an investor claim connected to her prior associations with Emerson Equity LLC and Arkadios Capital, focusing on alleged sales-practice violations tied to DST and other real estate securities. In one disclosure, Arkadios Capital reports a FINRA arbitration alleging violations of federal securities laws, the California Securities Act, Pennsylvania securities laws, and the Pennsylvania Unfair Trade Practices and Consumer Protection Law, along with breach of contract, common law fraud, breach of fiduciary duty, negligence, and gross negligence. The product identified is a real estate security, and the claimant seeks compensatory damages along with “benefit of the bargain” damages, lost opportunity costs, model portfolio damages, prejudgment interest, costs, attorneys’ fees, punitive damages, and other relief, with the exact amount to be determined by the arbitration panel. A parallel disclosure referencing both Emerson Equity LLC and Arkadios Capital alleges that, from March 14, 2022 through December 11, 2023, Romiti recommended allegedly unsuitable investment recommendations in several DST private placements. The customer claims these transactions were inappropriate in light of the investor’s objectives and risk tolerance. The Product Type is listed as “DSTs (Private Placements),” with damages again described as “TBD,” and the matter is proceeding in FINRA arbitration. Both disclosures are categorized as “Customer Dispute – Pending” and appear to relate to the same FINRA arbitration, Docket No. 25-02160, filed on October 21, 2025. The customer complaints were reported on October 21 and October 22, 2025, and remain pending with no settlement or final award reported as of the most recent BrokerCheck update. Romiti has not been the subject of any reported regulatory actions, criminal matters, or financial-related disclosures such as bankruptcies or judgments. For context, Romiti’s customer dispute disclosures can be summarized as follows: As with all pending customer disputes, these allegations have not been proven, and no finding of liability has been made against Romiti. The complaints may ultimately be denied, withdrawn, settled without an admission of wrongdoing, or adjudicated by a FINRA arbitration panel. In general, DST and other private placement offerings are often high-risk, illiquid investments that may not be appropriate for investors seeking capital preservation, liquidity, or conservative income strategies. When such products are concentrated in a client’s portfolio or sold without adequate disclosure of risks, they can lead to significant losses and potential sales-practice violations if the recommendations fail to align with the investor’s profile. To obtain a copy of Ashley Quinn Romiti’s FINRA BrokerCheck report, visit this link. Robert Wayne Pearce Is Committed to Recovering Your Investment Losses Detailed allegations that a broker recommended DST private placements that did not match a client’s objectives, risk tolerance, time horizon, income needs, or liquidity requirements often implicate FINRA Rule 2111 and related suitability standards. Our firm routinely litigates these issues in arbitration nationwide. Romiti’s pending customer disputes may indicate pattern concerns about whether her recommendations in real estate securities and DST private placements complied with suitability, disclosure, and supervisory rules. Even if your particular account is not part of the pending FINRA case, similar recommendations or product exposures in your portfolio may warrant independent review. FINRA Rule 2111 (Suitability) FINRA Rule 2111, the Suitability Rule, requires brokers 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. That profile includes factors such as age, financial situation, tax status, investment objectives, investment experience, time horizon, liquidity needs, and risk tolerance. The customer disputes involving Ashley Quinn Romiti allege that she recommended DST and real estate security investments that were unsuitable in light of the investor’s needs and circumstances, and that these recommendations caused losses. If a FINRA arbitration panel were to find that she failed to conduct adequate due diligence on the DST private placements, failed to understand or explain the associated risks, or recommended an over-concentration in illiquid alternative investments, it could conclude that Rule 2111 was violated. In a suitability case, the panel may look at whether the complexity and illiquidity of the private placements were appropriate for the investor’s objectives, whether the client’s financial profile could bear the potential losses, and whether the broker documented and updated the client’s profile appropriately before recommending the products at issue. If the recommendations were not reasonably tailored to the client’s circumstances, this may support liability under Rule 2111, subject to all evidence presented and the broker’s defenses. FINRA Rule 2010 (Standards of Commercial Honor and Principles...

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Citigroup Global Markets Broker Elijah Goble Under Investigation For Unsuitable Barrier Note and Improper Handling of Customer Account FINRA Complaints

Our firm is investigating Citigroup Global Markets Inc. broker and financial advisor Elijah Grant Goble (CRD# 6760147) of Costa Mesa, California for potential investment-related misconduct arising from customer complaints alleging an unsuitable coupon barrier note recommendation and improper handling of a municipal debt account. Elijah Grant Goble’s Financial Advisor Career History According to his FINRA BrokerCheck report, Elijah Grant Goble has been registered in the securities industry since 2017 and is currently licensed in numerous states and with multiple self-regulatory organizations. He is presently registered as a General Securities Representative and investment adviser representative with Citigroup Global Markets Inc. (CRD# 7059), working through Citi Retail Banking branch offices in Costa Mesa, California, and affiliated locations. He has been with Citigroup Global Markets Inc. since March 26, 2018. Goble’s prior investment-related employment includes: His non-investment-related background includes roles in live entertainment production and information technology support, as well as full-time college studies, before entering the securities industry. Elijah Grant Goble Fraud Allegations and Investor Complaints Explained FINRA BrokerCheck discloses two customer dispute events on Elijah Grant Goble’s record—one settled complaint involving a coupon barrier note and one pending FINRA arbitration alleging improper handling of a municipal debt account. These disclosures do not, by themselves, establish liability, but they do show that multiple customers have raised serious allegations about his recommendations and account handling. Settled Customer Complaint Involving Coupon Barrier Note In April 2022, a customer lodged an oral complaint against Citigroup Global Markets Inc. relating to a barrier note transaction handled by Goble. The client alleged that: Key details from the disclosure include: From an investor-protection perspective, the allegations focus on whether a complex, high-risk structured product was suitable for a customer who requested conservative investments and believed his downside risk was limited, and whether the risks and potential volatility of the barrier note were accurately explained. Summary of Settled Disclosure (Barrier Note) Pending FINRA Arbitration Alleging Improper Handling of Municipal Debt Account FINRA BrokerCheck also reports a pending arbitration filed in 2025 involving alleged improper handling of a municipal debt account at Citigroup Global Markets Inc. where Goble was the registered representative. According to the disclosure: Because the case is still pending, the allegations have not been adjudicated, and there has been no finding of liability or wrongdoing. Nonetheless, a claimed loss of more than $276,000 in a municipal debt account signals a significant dispute and raises questions about suitability, risk disclosure, monitoring, and overall account management. Summary of Pending Disclosure (Municipal Debt Account) Overview of Elijah Grant Goble’s Reported Disclosures In total, Elijah Grant Goble’s BrokerCheck record currently reflects: Investors reviewing these disclosures should recognize that the existence of complaints and pending arbitrations indicates serious customer concerns, but the ultimate outcome may depend on how arbitrators assess the evidence, including documents, testimony, and expert analysis. To obtain a copy of Elijah Grant Goble’s FINRA BrokerCheck report, visit this link. Robert Wayne Pearce Is Committed to Recovering Your Investment Losses FINRA Rule 2111 – Suitability In cases like the barrier note complaint reported against Elijah Grant Goble, FINRA Rule 2111 (the “Suitability” rule) is often central. Rule 2111 requires that a broker or associated person have a reasonable basis to believe that any recommended transaction or investment strategy is suitable for the customer based on information obtained through reasonable diligence, including the investor’s age, financial situation, tax status, risk tolerance, and investment objectives. When a customer instructs a broker to invest funds “conservatively” but is instead placed into an “extremely high risk” coupon barrier note that later experiences a steep decline in value—from $40,000 down to approximately $7,000 at one point—arbitrators may examine whether the broker: If the evidence shows that the broker recommended an overly risky structured product to a conservative investor, or failed to disclose material risks, arbitrators may find a violation of Rule 2111 and award damages for resulting losses. FINRA Rule 2010 – Standards of Commercial Honor and Just and Equitable Principles of Trade FINRA Rule 2010 requires that brokers and associated persons “observe high standards of commercial honor and just and equitable principles of trade” in the conduct of their business. While Rule 2111 addresses suitability directly, Rule 2010 is broader and often used in combination with more specific rule violations. In the context of Goble’s reported disclosures, arbitrators and regulators may analyze whether the alleged improper handling of a municipal debt account—resulting in claimed damages of more than $276,000—reflected conduct that fell short of these high standards. For example, if a broker: such behavior may be viewed as inconsistent with the just and equitable principles required under Rule 2010, even apart from any specific suitability violation. In many arbitration awards and disciplinary actions, a pattern of poor judgment and disregard for customer interests is framed as a Rule 2010 violation. FINRA Rule 2210 – Communications with the Public FINRA Rule 2210 governs broker communications with the public, including written materials, electronic communications, and certain oral presentations that are memorialized or widely distributed. The rule requires that communications be fair and balanced and that they provide a sound basis for evaluating the facts regarding any security or investment strategy, without omitting material information or understating risks. In a case where a customer alleges that he was told the most he could lose on a barrier note was 30%, but the investment later experienced much steeper losses, arbitrators may look at how the product was described: If a broker’s explanations or marketing-style communications about a structured note or municipal debt strategy were misleading, overly promotional, or omitted key risk information, arbitrators may find that those communications violated Rule 2210. Such findings often bolster an investor’s claims for recovery when combined with allegations of unsuitability and breach of duty. 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...

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PHX Financial Broker Alex Ng Under Investigation For Unsuitable Investments and Misrepresentation FINRA Complaint

Alex Ng (CRD# 5842211) is a PHX Financial, Inc. stockbroker and investment adviser representative based in New York, New York, who is currently the subject of multiple pending FINRA customer disputes involving allegedly unsuitable investments and misrepresentation. Stockbroker Alex Ng’s Career History Alex Ng has spent his entire securities career in the New York market with a small number of brokerage and advisory firms: He is currently registered as a General Securities Representative with FINRA and licensed as a securities agent in more than 40 U.S. states and territories. Alex Ng’s Other Business Activities According to his Form U4, Ng also reports ownership of ALEX KING NG LLC, a business he uses to pay bills for his practice, which he indicates requires approximately 10 hours per month and no time during trading hours. Alex Ng Fraud Allegations and Investor Complaints Explained FINRA’s BrokerCheck report for Alex Ng discloses two pending customer disputes filed in 2025, both seeking substantial damages and arising from PHX Financial customer accounts. 2025 FINRA Arbitration Claim Alleging Unsuitable Reallocation of Portfolio In the first pending matter, a group of clients allege that, after they transferred their account to Ng at PHX Financial, he reallocated their portfolio into allegedly unsuitable investments: blue-chip stocks, sector funds, and alternative investments. The customers contend that this shift in strategy exposed them to excessive risk and losses inconsistent with their investment profiles. Key details reported to FINRA include: Ng has submitted a statement denying any wrongdoing, asserting that his clients’ accounts were profitable while he managed them and indicating he intends to seek expungement of the complaint once the matter is resolved. 2025 FINRA Arbitration Claim Alleging Misrepresentation, Negligence, and Breach of Fiduciary Duty The second pending dispute also arises from Ng’s time at PHX Financial and involves even broader accusations. In that case, a client alleges: The products at issue include both listed equities and private equity investments. The customer seeks damages between $500,000 and $1,000,000, again through a FINRA arbitration proceeding. Case details reported to BrokerCheck: Ng again denies all allegations, stating that the client’s account was profitable while he managed it and that he plans to pursue expungement after the arbitration concludes. Summary of Alex Ng’s FINRA Disclosures As of the most recent BrokerCheck report, Alex Ng’s publicly reported disclosures include: Investors should understand that these matters are currently unresolved. Allegations in pending FINRA proceedings have not been proven and may ultimately be denied, dismissed, or settled without any finding of liability against the broker or the firm. To obtain a copy of Alex Ng’s FINRA BrokerCheck report, visit this link. Robert Wayne Pearce Is Committed to Recovering Your Investment Losses FINRA Rule 2111 – Suitability Obligations FINRA Rule 2111 (Suitability) requires brokers like Alex Ng to have a reasonable basis to believe that each recommended transaction or overall investment strategy is suitable for the customer in light of that customer’s investment profile—age, financial situation, risk tolerance, investment objectives, and other factors. When clients allege that Ng reallocated their accounts into concentrated positions in blue-chip stocks, sector funds, and alternative or private investments that did not match their needs, they are effectively claiming a violation of Rule 2111’s “reasonable basis” and “customer-specific” suitability standards. If a broker recommends a strategy that exposes customers to more volatility, liquidity risk, or downside risk than their profiles support—and particularly if those recommendations generate higher commissions or fees for the broker—that conduct may be deemed unsuitable under Rule 2111 and form the basis for an arbitration claim seeking to recover losses. FINRA Rule 2010 – Standards of Commercial Honor and Principles of Trade FINRA Rule 2010 requires associated persons to “observe high standards of commercial honor and just and equitable principles of trade.” Allegations of misrepresentation, negligence, and breach of fiduciary duty go beyond mere poor judgment; they suggest conduct that may fall short of these ethical standards. In the pending cases against Ng, the customers claim that he misrepresented or failed to fully disclose the risks and characteristics of the recommended investments and that his conduct breached duties owed to them. If a FINRA arbitration panel finds that a broker’s recommendations were dishonest, misleading, or inconsistent with fair dealing—even if they technically comply with some other rule—the panel may conclude that Rule 2010 was violated, further supporting an award of damages to investors. FINRA Rule 2210 – Communications with the Public FINRA Rule 2210 governs a broker’s communications with the public, including written and oral statements made to customers about securities and investment strategies. It prohibits false, exaggerated, unwarranted, or misleading statements and requires that communications provide a fair and balanced treatment of risks and potential benefits. The customer dispute alleging misrepresentation and negligent conduct implicitly raises Rule 2210 concerns. If Ng or PHX Financial presented private equity or other securities as safer, more liquid, or more income-producing than they truly were—or omitted important risk disclosures—those communications could be deemed misleading under Rule 2210. When a communication fails to give investors a fair picture of the risks involved, and clients rely on that incomplete or biased information to approve the transaction, any resulting losses may be recoverable in investment loss claims brought through FINRA arbitration or related litigation. 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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Raymond James & Associates Broker William Bredt Under Investigation For Unsuitable Private Placement and REIT Recommendations FINRA Complaint

Our firm is investigating Raymond James & Associates, Inc. broker and investment adviser representative William Roy Bredt (CRD# 1621507) of West Conshohocken, Pennsylvania for potential investment-related misconduct involving alleged unsuitable private placement and REIT recommendations, misrepresentations of risks, and other sales-practice violations. Financial Advisor’s Career History William Roy Bredt has worked in the securities industry since the late 1980s. FINRA BrokerCheck shows that he is currently registered as a General Securities Representative and investment adviser representative with Raymond James & Associates, Inc. and is licensed across numerous self-regulatory organizations and more than forty U.S. states and territories. According to his registration and employment history: BrokerCheck also reflects that Bredt has passed the Series 7, Series 63, and Series 65 examinations and holds active registrations with nine self-regulatory organizations and 41 U.S. states and territories through Raymond James & Associates, Inc. William Roy Bredt Fraud Allegations and Investor Complaints Explained FINRA disclosure records show eight customer dispute events involving William Roy Bredt: one pending customer complaint and seven final customer disputes (including both settled and denied/closed matters). The allegations focus on unsuitable investment recommendations, misrepresentations, churning, failure to follow instructions, and issues with private placements and REIT products. 2025 Pending REIT and Private Placement Complaint – $400,000 Alleged Damages A 2025 customer complaint remains pending against Bredt, reported under Raymond James & Associates, Inc.: This pending dispute centers on complex real estate securities, where customers commonly claim that they were not adequately informed of liquidity risks, potential principal loss, and income variability associated with REIT and private placement offerings. 2025 Denied Private Placement Structural-Defect Complaint BrokerCheck lists a 2025 written customer complaint involving a private placement that Raymond James & Associates, Inc. denied: 2025 Denied Complaint Over Fees and Lack of Service Another 2025 written complaint alleges fee-based mismanagement and lack of ongoing advice: 2024 Unsuitable Account-Type Complaint – Denied in 2025 FINRA records also show a written customer complaint alleging that the account type itself was unsuitable: The customer contends that the structure and risk profile of the account did not match their investment objectives and risk tolerance, raising suitability concerns regarding how the portfolio was designed and managed over multiple years. 2009 Direct Investment Complaint – Denied Another earlier written complaint involved a direct participation program (DPP) or limited partnership (LP) interest. Although the firm ultimately denied the claim and reported no settlement, these allegations again focus on a non-traded or illiquid alternative investment that allegedly failed to perform as expected. 1999 Equity Complaint – Poor Performance and Churning Allegations BrokerCheck reports a 1999 complaint involving allegations of “poor performance/churning” in an equity account: While the firm closed the matter without action, “churning” allegations typically suggest that the customer believed there was excessive trading in the account designed to generate commissions rather than serve the investor’s best interests. 2008–2009 Settled Complaint – Failure to Follow Instructions Bredt’s record includes a customer complaint that ultimately resulted in a monetary settlement: The firm had previously denied the claim, but ultimately entered into a settlement, which can indicate a business decision to resolve the dispute rather than continue with protracted litigation or arbitration. 1997 Wheat First Securities Arbitration – Unsuitable Trading and Churning (Settled) Regulatory and broker-reported entries show a 1997 NASD arbitration involving Wheat First Securities: Summary of FINRA Disclosures Based on the BrokerCheck report, Bredt’s disclosure history currently reflects: All of these disclosures involve allegations, and Bredt has denied wrongdoing in several BrokerCheck statements. No regulatory discipline or criminal events are reported in the material reviewed. To obtain a copy of William Roy Bredt’s FINRA BrokerCheck report, visit this link. Robert Wayne Pearce Is Committed to Recovering Your Investment Losses FINRA Rule 2111 – Suitability FINRA Rule 2111 requires brokers to have a reasonable basis to believe that each recommendation is suitable for the customer based on the customer’s investment profile, including age, financial situation, investment experience, risk tolerance, and liquidity needs. In the pending 2025 complaint, the customer alleges that Bredt recommended an unsuitable private placement and REIT investment, misrepresented its returns and risks, and caused losses of approximately $400,000. Similar suitability concerns arise in the 2024 complaint alleging that the account type was unsuitable, as well as historical allegations of unsuitable trading and churning in earlier accounts. When complex or illiquid products such as REITs, private placements, and DPP/LP interests are recommended to investors who need principal protection or liquidity, there can be a strong argument that the broker failed to satisfy his obligations under FINRA Rule 2111. FINRA Rule 2010 – Standards of Commercial Honor and Just and Equitable Principles of Trade FINRA Rule 2010 is a broad conduct rule requiring brokers to observe high standards of commercial honor and just and equitable principles of trade. Even when there is no separate regulatory action, repeated customer complaints alleging misrepresentations, omissions, failure to follow instructions, churning, or failure to provide promised advisory services can raise concerns under Rule 2010. The complaints against Bredt include allegations that he failed to follow client instructions over a long period (2001–2008), that clients paid management fees without receiving adequate advice, and that accounts were subject to poor performance or excessive trading. If proven, such conduct may be considered inconsistent with Rule 2010’s requirement that brokers act fairly, honestly, and in good faith when dealing with customers. FINRA Rule 2210 – Communications with the Public FINRA Rule 2210 governs broker communications with the public, including written marketing materials, pitch books, and other sales communications. The rule is designed to ensure that communications are fair and balanced, not misleading, and that they provide a sound basis for evaluating the facts regarding any investment. Some of the complaints involving Bredt allege misrepresentations and omissions about the structure, risks, or performance characteristics of private investments and equity strategies. For example, one client claims that representations about a private investment failed to account for “weakness and structural defects,” while other disputes raise concerns about how complex or illiquid products were presented to investors. To the extent that...

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Janssen Partners Broker Peter Janssen Under Investigation For Alleged Unsuitable Private Placements and Misrepresentation FINRA Complaint

Peter Kyle Janssen (CRD# 5691028). Our firm is investigating Janssen Partners, Inc. broker and financial advisor Peter Kyle Janssen (CRD# 5691028) of Fairfield, Iowa for potential investment-related misconduct involving private placements and other alternative investments. Financial Advisor’s Career History According to FINRA BrokerCheck, Peter Kyle Janssen has been registered in the securities industry since 2011. He is currently registered as a General Securities Representative with Janssen Partners, Inc. (CRD# 43940) in Fairfield, Iowa, where he has been associated since December 21, 2022. Janssen has been registered with the following broker-dealers over the course of his career: He is currently licensed in multiple states, including California, Florida, Nevada, New York, and Texas. Other Business Activities and Crypto Fund In addition to his brokerage work, FINRA records show that Janssen is the manager of FirstBlock Capital Fund I, LP, an investment fund focused on crypto assets, located in Delray Beach, Florida. He reports that he manages the fund and operations using a buy-and-hold strategy and spends several hours per week on this activity during trading hours. Peter Kyle Janssen Fraud Allegations and Investor Complaints Explained FINRA BrokerCheck for Peter Kyle Janssen discloses four customer disputes, including one arbitration award to a customer and three settled customer complaints. All of the matters are investment-related and involve allegations of misrepresentation, negligence, breach of fiduciary duty, and unsuitable private placement investments—particularly in high-risk offerings such as Mega Blockchain and NewEdge Signal Solution Inc. FINRA Arbitration Award – Mega Blockchain Private Placement (Case No. 23-00044) In a FINRA arbitration case filed in January 2023 (FINRA Case No. 23-00044), a customer alleged that while associated with Katalyst Securities LLC, Peter Kyle Janssen engaged in: The allegations arose from a December 2017 investment in a Mega Blockchain offering, which the firm and Janssen described as a private placement involving exposure to the cryptocurrency market. The customer alleged that Janssen misrepresented the terms of the offering and recommended an investment that was unsuitable for her risk profile. The customer invested approximately $94,930.40 in the Mega Blockchain private placement. Key details include: This award suggests the arbitrators determined there were significant issues with how the Mega Blockchain private placement was recommended and sold to the customer. Settled Customer Complaint – NewEdge Signal Solution Inc Private Placement (Alleged Damages $200,000) Another customer dispute reported on Janssen’s BrokerCheck involves a private placement investment in NewEdge Signal Solution Inc while he was a registered representative of Katalyst Securities LLC. The firm disclosure states that: The broker’s version of the disclosure characterizes the customer as a sophisticated investor who had purchased multiple private placements totaling approximately $1.5 million, but who later alleged that one $200,000 private placement was unsuitable. Settled Customer Complaint – Mega Blockchain Private Placement (Alleged Damages $50,000) A separate customer complaint relates to another Mega Blockchain private placement sold through Katalyst Securities LLC. FINRA records reflect that: The firm statement emphasizes that the settlement was reached to avoid the cost of protracted litigation and that Katalyst denied any wrongdoing. Settled Customer Complaint – Mega Blockchain Private Placement (Alleged Damages $30,000) A third settled matter also involves an investment in the Mega Blockchain private placement while Janssen was associated with Katalyst Securities LLC. The disclosure indicates that: Taken together, these disclosures show a pattern of customer disputes stemming from concentrated activity in speculative private placements, including Mega Blockchain and NewEdge Signal Solution Inc, along with allegations of misrepresentation and unsuitability. Summary of Disclosed Customer Disputes To obtain a copy of Peter Kyle Janssen’s FINRA BrokerCheck report, visit this link. Robert Wayne Pearce Is Committed to Recovering Your Investment Losses FINRA Rule 2111 (Suitability) FINRA Rule 2111, the Suitability Rule, requires that a broker or firm 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, and liquidity needs. In the disputes involving Mega Blockchain and NewEdge Signal Solution Inc, customers alleged that Janssen recommended speculative private placements that were unsuitable for their circumstances and risk tolerance. When a broker recommends highly illiquid, high-risk private placements—especially in sectors like cryptocurrency—Rule 2111 requires: If Janssen recommended Mega Blockchain or NewEdge private placements without fully considering whether the customers could withstand the potential total loss of principal, illiquidity, or volatility associated with such offerings, or if he relied too heavily on bare accredited-investor representations without deeper inquiry into goals and risk tolerance, that conduct may be inconsistent with FINRA Rule 2111. FINRA Rule 2010 (Standards of Commercial Honor and Just and Equitable Principles of Trade) FINRA Rule 2010 requires brokers to “observe high standards of commercial honor and just and equitable principles of trade” in all of their business dealings. The rule is intentionally broad and is often cited in cases involving misrepresentation, fraud, breach of fiduciary duty, or other unethical conduct. You can learn more about this rule and how it is applied to broker misconduct on the firm’s FINRA Rule 2010 resource page. In the FINRA arbitration award and the settled claims against Janssen, customers alleged negligence, fraud, breach of fiduciary duty, and misleading statements in connection with private placement offerings. Even where a customer qualifies as an “accredited investor,” a broker cannot: When an arbitrator awards damages to a customer—particularly in a case involving allegations of fraud and misrepresentation—it often reflects a conclusion that the broker’s conduct fell below the “high standards of commercial honor” required by Rule 2010, even if the broker denies intentional wrongdoing. A pattern of similar complaints involving the same product (such as multiple Mega Blockchain disputes) can be especially problematic under this rule. FINRA Rule 2210 (Communications with the Public) FINRA Rule 2210 governs broker communications with the public, including written presentations, offering materials, pitch decks, and marketing emails used to sell private placements and other investments. The rule requires that all such communications be fair and balanced, not misleading, and that they provide a sound basis for evaluating the facts...

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