Bad Brokers

According to FINRA, Mark Elliot Paverman was fined $20,000, suspended from association with any FINRA member firm in any principal capacity for 12 months (effective February 17, 2026 through February 16, 2027), and required to requalify by examination as a General Securities Principal before resumin...

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According to FINRA, Mark Elliot Paverman was fined $20,000, suspended from association with any FINRA member firm in any principal capacity for 12 months (effective February 17, 2026 through February 16, 2027), and required to requalify by examination as a General Securities Principal before resuming that role, for causing his member firm to fail to maintain required books and records and for making a false certification to FINRA regarding the firm's record retention arrangements.FINRA found that the firm, acting through Paverman, failed to preserve electronic communications of three of its registered representatives, failed to preserve instant messages for any of its registered representatives, and failed to preserve electronic communications of affiliated personnel at the firm's corporate parent who performed brokerage functions. These records are required to be preserved under Exchange Act Rules 17a-3 and 17a-4, which exist to ensure that regulators and investors have access to documentation of broker-dealer business activities if questions or disputes arise.Paverman also made a false certification to FINRA, representing that his firm had directly contracted with a vendor for record retention services and that the firm had independent access to the records maintained by that vendor. In fact, the contract was between the vendor and the firm's corporate parent—not the firm itself. The firm also did not have independent access to those records. As a result of this false certification, Paverman was unable to provide FINRA with requested information during its examination.Accurate record-keeping and honest certifications to regulators are foundational obligations for broker-dealers and their principals. When principals certify inaccurate information to FINRA, they undermine the regulator's ability to assess compliance and protect investors.For investors, this case illustrates that record-keeping is not just a technical compliance matter—it directly affects the ability of regulators and investors to reconstruct what happened in an advisory relationship if a dispute arises. Investors who believe their broker may not be maintaining proper records should contact FINRA or file a complaint through FINRA's investor complaint portal. Checking FINRA BrokerCheck can also reveal any prior regulatory actions against a broker or principal.

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According to FINRA, Christian Gonzalez was assessed a deferred fine of $5,000 and suspended from association with any FINRA member firm in all capacities for 12 months, effective February 2, 2026 through February 1, 2027, for making a series of cash deposits structured specifically to avoid triggeri...

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According to FINRA, Christian Gonzalez was assessed a deferred fine of $5,000 and suspended from association with any FINRA member firm in all capacities for 12 months, effective February 2, 2026 through February 1, 2027, for making a series of cash deposits structured specifically to avoid triggering federal currency transaction reporting requirements—a practice known as structuring.FINRA found that Gonzalez made cash deposits in a firm account totaling $58,970, with each individual deposit in an amount deliberately kept below the $10,000 threshold that triggers mandatory Currency Transaction Report (CTR) filing under the Bank Secrecy Act (BSA). Financial institutions, including broker-dealers, are required under the BSA to file CTRs for all cash transactions exceeding $10,000. Structuring—deliberately breaking up transactions to avoid the $10,000 reporting threshold—is itself a federal crime under 31 U.S.C. § 5324, separate from any other underlying illegal activity.FINRA found that Gonzalez had received Bank Secrecy Act training from his member firm specifically informing him that financial institutions are required to report cash transactions over $10,000 and that structuring is prohibited. Despite this training, he deliberately made deposits in sub-threshold amounts to evade reporting. The total amount deposited—$58,970—would have generated CTR filings if deposited in a single or fewer transactions, which appears to have been the motivation for breaking the amounts apart.Anti-money laundering laws and reporting requirements exist to help law enforcement detect and investigate money laundering, tax evasion, and other financial crimes. Structuring deprives regulators of visibility into potentially suspicious financial activity and can facilitate broader criminal conduct. The fact that Gonzalez received explicit training on BSA requirements makes this violation particularly serious.For investors, this case serves as a reminder that the securities industry is subject to robust anti-money laundering oversight, and that broker-dealers have legal obligations to detect and report suspicious financial transactions. Investors who observe suspicious cash handling by a broker or firm representative should report their concerns to the firm's compliance department, FINRA, or the Financial Crimes Enforcement Network (FinCEN).

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According to FINRA, Boustead Securities, LLC, Sutter Securities Incorporated, and their CEO Keith Charles Moore are facing charges in a FINRA complaint filed in January 2026 alleging widespread failures in anti-money laundering compliance, supervisory systems, books and records obligations, and new ...

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According to FINRA, Boustead Securities, LLC, Sutter Securities Incorporated, and their CEO Keith Charles Moore are facing charges in a FINRA complaint filed in January 2026 alleging widespread failures in anti-money laundering compliance, supervisory systems, books and records obligations, and new issue distribution rules. These are allegations in a complaint—findings have not yet been made, and the matter remains pending.The complaint alleges that Moore served as CEO of both Irvine, California-based firms and as the AML Compliance Officer (AMLCO) for both, and that he failed to implement a reasonable AML program at either firm despite being aware of red flags related to the firms' underwriting and syndication activities involving customers and issuers in foreign jurisdictions. The complaint further alleges that neither firm established AML policies and procedures for ongoing monitoring, customer due diligence, or identifying and reporting suspicious transactions—including potential nominee activity and market manipulation.With respect to supervisory failures, the complaint alleges that Boustead failed to routinely review trade or order blotters for suspicious activity, while Sutter relied on cursory manual review by an untrained representative. Neither firm allegedly conducted order-level surveillance for potential market manipulation. Both firms allegedly failed to establish WSPs reasonably designed to comply with Regulation M, which prohibits certain market participants from bidding for or purchasing securities during a restricted period. Boustead allegedly repeatedly misidentified the commencement date of the applicable restricted period, excluding dates that fell within the period mandated by Regulation M.The complaint also alleges that Boustead failed to retain business-related communications conducted through WhatsApp and WeChat—even after purportedly approving WeChat use subject to a required third-party retention application that was never actually implemented. Boustead is alleged to have failed to disclose approximately $1.25 million in underwriting compensation received in connection with a May 2021 IPO. Separately, Sutter is alleged to have repeatedly sold new issue securities to accounts in which restricted persons—immediate family members of Sutter representatives—held beneficial interests, in violation of FINRA Rule 5130.Because this is an unadjudicated complaint, FINRA advises that readers may wish to contact the respondents before drawing conclusions. For investors, the alleged conduct reflects the potential risks in small broker-dealers conducting complex capital markets activities without robust compliance infrastructure. Investors who participated in IPOs or private placements through either firm may wish to review their records and consult FINRA BrokerCheck.

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According to FINRA, Tory A. Duggins was named as a respondent in a FINRA complaint filed in January 2026, alleging that he failed to provide on-the-record testimony requested by FINRA as part of an investigation into whether he churned and excessively traded customer accounts. This is an unadjudicat...

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According to FINRA, Tory A. Duggins was named as a respondent in a FINRA complaint filed in January 2026, alleging that he failed to provide on-the-record testimony requested by FINRA as part of an investigation into whether he churned and excessively traded customer accounts. This is an unadjudicated complaint—findings have not been made, and FINRA advises that readers may wish to contact the respondent before drawing any conclusions regarding the allegations.According to the complaint, Duggins initially cooperated with FINRA's investigation, producing documents including financial statements in response to a request. However, he subsequently failed to appear for on-the-record testimony on three separate occasions and did not contact FINRA to reschedule or provide an explanation for his absences. The testimony requested of Duggins was described as material to FINRA's investigation into his potential misconduct.Churning—also known as excessive trading—is one of the most harmful forms of broker misconduct. It occurs when a broker makes frequent, unnecessary trades in a customer's account primarily to generate commissions, rather than to further the customer's investment objectives. Churning can erode a customer's portfolio through accumulated transaction costs and taxes, and it represents a fundamental breach of the duty a broker owes to clients. FINRA has a formal investigation process for examining whether trading patterns in customer accounts are consistent with legitimate investment strategies or suggest churning.Refusing to appear for on-the-record testimony after initially cooperating is itself a potential violation of FINRA Rule 8210, which requires all registered persons to cooperate with FINRA's regulatory oversight process. The complaint reflects FINRA's intent to formally adjudicate both the underlying alleged misconduct and Duggins' refusal to testify.For investors, this case is a reminder to regularly review brokerage statements for excessive trading activity. High turnover rates, frequent purchases and sales of similar securities, and unusually high commissions relative to account value are potential signs of churning. Investors who suspect excessive trading should file a complaint with FINRA and consider consulting an attorney or their state securities regulator.

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According to FINRA, Dealer Solutions North America LLC was expelled from FINRA membership in January 2026 for failure to provide information or keep information current as required under FINRA Rule 9552. The expulsion became effective January 22, 2026.FINRA Rule 9552 establishes a process by which F...

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According to FINRA, Dealer Solutions North America LLC was expelled from FINRA membership in January 2026 for failure to provide information or keep information current as required under FINRA Rule 9552. The expulsion became effective January 22, 2026.FINRA Rule 9552 establishes a process by which FINRA may suspend or expel a member firm that fails to comply with its obligations to provide information requested by FINRA or to keep its regulatory filings and disclosures current. These obligations are foundational to FINRA's ability to regulate member firms and protect investors. When a firm fails to meet these requirements, FINRA initiates a summary suspension process, and if the firm does not cure the failure within a specified period, the suspension can be converted to expulsion.Expulsion from FINRA membership is the most severe sanction available against a member firm. An expelled firm is no longer permitted to conduct a securities business as a FINRA member and cannot hold customer accounts or execute securities transactions in that capacity. Customers of expelled firms should promptly transfer their accounts to another FINRA-registered broker-dealer and review their account history for any concerns.The limited public information available for Rule 9552 actions means that the specific nature of the information failure or disclosure deficiency is not detailed in this report. Investors who had accounts at Dealer Solutions North America LLC should check FINRA BrokerCheck for the firm's regulatory history and contact FINRA's investor services line for assistance with account transfers or concerns about prior transactions. Maintaining current and accurate regulatory information is a basic obligation of every FINRA member, and the failure to do so deprives regulators of the ability to monitor a firm's fitness to conduct a securities business.

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According to FINRA, Flair Portal, LLC, a registered funding portal based in Vancouver, Canada, was expelled from FINRA in January 2026 for failure to provide information or keep information current as required under FINRA Rule 9552. The expulsion became effective January 27, 2026.Flair Portal was a ...

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According to FINRA, Flair Portal, LLC, a registered funding portal based in Vancouver, Canada, was expelled from FINRA in January 2026 for failure to provide information or keep information current as required under FINRA Rule 9552. The expulsion became effective January 27, 2026.Flair Portal was a registered funding portal—an entity authorized under FINRA rules to facilitate securities offerings under the crowdfunding provisions of the JOBS Act. Funding portals are subject to FINRA's regulatory oversight, including requirements to maintain current registration information and to respond to FINRA's requests for information. When a funding portal fails to meet these obligations, FINRA may initiate a summary suspension and expulsion process under Rule 9552.Expulsion is the most serious sanction FINRA can impose on a member organization. An expelled funding portal is no longer permitted to operate as a FINRA-registered entity and cannot facilitate securities offerings in that capacity. Investors who participated in crowdfunding offerings through Flair Portal should review their investment records and verify the status of any securities they purchased through the platform.The specific nature of Flair Portal's information failure is not detailed in the public disciplinary report. However, the failure to maintain current regulatory information and respond to FINRA's oversight requests is a fundamental compliance failure that undermines investor protection. Investors who used Flair Portal as a crowdfunding platform should contact FINRA for assistance and should be aware that crowdfunding investments made through expelled entities may present unique challenges in terms of liquidity, ongoing disclosures, and investor recourse. FINRA BrokerCheck and FINRA's funding portal registration database can be consulted for additional information.

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According to FINRA, Fundit, Inc., a registered funding portal based in Fairfield, New Jersey, was suspended by FINRA in January 2026 for failure to provide information or keep information current as required under FINRA Rule 9552. The suspension became effective January 16, 2026.Funding portals like...

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According to FINRA, Fundit, Inc., a registered funding portal based in Fairfield, New Jersey, was suspended by FINRA in January 2026 for failure to provide information or keep information current as required under FINRA Rule 9552. The suspension became effective January 16, 2026.Funding portals like Fundit are authorized under FINRA rules to facilitate crowdfunding securities offerings for small businesses and startups, operating under the regulatory framework established by the JOBS Act. These entities are subject to FINRA oversight, including requirements to maintain current registration information and cooperate with FINRA's regulatory requests. When a funding portal fails to comply with these obligations, FINRA may suspend it under Rule 9552(d), which provides a process for summary suspension of member organizations that fail to provide required information or maintain current registration disclosures.A suspension prevents the portal from conducting its regulated activities during the suspension period. If the deficiency is not cured, the suspension can escalate to expulsion. Unlike expulsion, suspension allows a firm to restore its FINRA membership status by curing the underlying deficiency within the applicable timeframe.Investors who participated in crowdfunding offerings facilitated by Fundit should monitor the situation closely and review their investment documentation. Crowdfunding investments are generally illiquid and carry significant risk. The suspension of a funding portal does not necessarily affect the underlying securities issued through the platform, but investors should be aware of any changes in the portal's status as they could affect ongoing disclosures and investor communications. FINRA's funding portal registration database and BrokerCheck can be consulted for additional information about Fundit's regulatory status.

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According to FINRA, Edwin Barkhordarian was permanently barred from association with any FINRA member firm in January 2026 pursuant to FINRA Rule 9552(h), for failure to provide information or keep information current as required by FINRA rules. The bar became effective January 27, 2026.FINRA Rule 9...

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According to FINRA, Edwin Barkhordarian was permanently barred from association with any FINRA member firm in January 2026 pursuant to FINRA Rule 9552(h), for failure to provide information or keep information current as required by FINRA rules. The bar became effective January 27, 2026.FINRA Rule 9552(h) authorizes FINRA to permanently bar an individual from the securities industry when that person fails to comply with requirements to provide information or keep registration information current, and the person does not cure the deficiency within the applicable timeframe. This rule is designed to protect investors by ensuring that individuals who fail to maintain transparency with their regulator cannot continue to operate in the securities industry.The specific circumstances underlying the information failure in this case are not detailed in the public disciplinary report. However, a permanent bar under Rule 9552(h) means that Barkhordarian is no longer permitted to associate with any FINRA member firm in any capacity. Investors who worked with Barkhordarian should review their account history for any concerns and can access his full regulatory record through FINRA BrokerCheck. The transparency of FINRA's registration system depends on all registered individuals maintaining current and accurate information—when individuals fail to do so and refuse to cure the deficiency, permanent removal from the industry is the appropriate regulatory response to protect the investing public.

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According to FINRA, Matthew Vernon Brosh was permanently barred from association with any FINRA member firm in January 2026 pursuant to FINRA Rule 9552(h), for failure to provide information or keep information current as required by FINRA rules. The bar became effective January 20, 2026.FINRA Rule ...

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According to FINRA, Matthew Vernon Brosh was permanently barred from association with any FINRA member firm in January 2026 pursuant to FINRA Rule 9552(h), for failure to provide information or keep information current as required by FINRA rules. The bar became effective January 20, 2026.FINRA Rule 9552(h) provides a mechanism for permanently barring individuals who fail to comply with FINRA's information requirements and do not cure the deficiency within a specified period. The obligation to maintain current registration information and cooperate with FINRA's regulatory oversight is a foundational requirement for all registered persons in the securities industry. This transparency supports FINRA's ability to monitor industry participants and supports public access to accurate broker registration information through tools like FINRA BrokerCheck.The specific circumstances underlying the information failure in this case are not detailed in the public disciplinary report. However, a permanent bar means that Brosh is no longer permitted to associate with any FINRA member firm in any capacity. Investors who worked with Brosh should review their account history for any concerns and may consult FINRA BrokerCheck for his full regulatory record. When registered individuals fail to maintain transparency with their regulator and refuse to cure disclosure deficiencies, permanent removal from the industry ensures that investors are protected from ongoing exposure to individuals operating outside FINRA's oversight framework.

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According to FINRA, Michael Robert Greenfield was permanently barred from association with any FINRA member firm in January 2026 pursuant to FINRA Rule 9552(h), for failure to provide information or keep information current as required by FINRA rules. The bar became effective January 26, 2026.FINRA ...

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According to FINRA, Michael Robert Greenfield was permanently barred from association with any FINRA member firm in January 2026 pursuant to FINRA Rule 9552(h), for failure to provide information or keep information current as required by FINRA rules. The bar became effective January 26, 2026.FINRA Rule 9552(h) authorizes the permanent bar of individuals who fail to comply with their obligation to provide information or maintain current registration disclosures, and who do not cure the deficiency within the specified timeframe. All registered persons in the securities industry are required to maintain current and accurate information with FINRA, including through timely updates to their registration filings and by responding to FINRA's regulatory requests. This ongoing transparency requirement allows FINRA to monitor the fitness of industry participants and enables investors to access accurate background information through tools like BrokerCheck.The specific circumstances underlying the information failure are not detailed in the public disciplinary report for this matter. However, the permanent bar means Greenfield may no longer associate with any FINRA member firm in any capacity. Investors who worked with Greenfield should review their account history for any concerns and may consult FINRA BrokerCheck for his complete regulatory record. A permanent bar is FINRA's most severe sanction against an individual and signals that the regulator determined Greenfield's failure to maintain required transparency warranted his permanent exclusion from the securities industry.

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