According to FINRA, Hugh Ordway Barndollar III was assessed a deferred fine of $10,000 and suspended for two years in all capacities for participating in unapproved private securities transactions totaling $1,418,108.

Barndollar served as both a registered representative of his member firm and an investment advisor representative. His firm placed him on heightened supervision due to customer arbitrations involving alleged sales practice violations. The heightened supervision plan prohibited him from selling alternative investments through the firm.

Despite this prohibition, Barndollar participated in sales of $742,058 in alternative investments after the heightened supervision began, through a registered investment advisory firm. Most investors were firm customers. Barndollar recommended and/or facilitated the investments, including meeting with investors to discuss them and assisting with documentation. His advisory clients paid advisory fees on assets in their advisory accounts, including the alternative investments.

While Barndollar disclosed his advisory firm as an outside business activity, stating he managed accounts on a fee-based platform with third-party money managers, he did not provide prior written notice of his participation in selling alternative investments through the advisory firm or obtain the firm's written approval. Furthermore, he falsely certified on annual compliance questionnaires that he had not engaged in undisclosed private securities transactions.

This conduct is particularly egregious because Barndollar was under heightened supervision specifically due to sales practice concerns, yet deliberately circumvented the supervision plan's prohibition on alternative investment sales. His false certifications compounded the violation by actively misleading the firm.

The two-year suspension holds Barndollar accountable for substantial private securities transactions in violation of heightened supervision restrictions and false compliance certifications.