According to FINRA, David Richard Ravarino of Concord, California was assessed a deferred fine of $10,000 and suspended from association with any FINRA member in all capacities for six months for engaging in outside business activities without full disclosure to his member firms.

In 2016, Ravarino formed a limited liability company purportedly to identify potential real estate investments. However, he actually used the LLC to provide consulting services to a third-party administrator serving retirement plans. These services included administrative tasks, strategic planning, and customer referrals.

The company paid Ravarino approximately $600,000 through the LLC for these services. Despite this substantial compensation, Ravarino did not notify his firms of the consulting arrangement until February 2024.

Although Ravarino disclosed to each firm that he owned the LLC, he falsely stated that his activities were limited to real estate and that he received only $1,500 annually—a dramatic understatement of the actual $600,000 he received.

Ravarino also falsely stated on multiple firm compliance questionnaires that he had disclosed all outside business activities.

The discrepancy between $1,500 and $600,000 in compensation is substantial and demonstrates deliberate misrepresentation rather than oversight. Firms rely on accurate OBA disclosures to evaluate conflicts of interest and ensure representatives are focused on their duties to customers.

The consulting relationship with a retirement plan administrator could create conflicts if Ravarino was referring his brokerage customers to the company or if his recommendations were influenced by this relationship.

The suspension is in effect from May 19 through November 18, 2025.

Investors should understand their broker's outside business activities and how they might affect recommendations.