According to FINRA, James Daniel Lang was fined $5,000 and suspended from association with any FINRA member in all capacities for four months for engaging in outside business activities without prior written disclosure to his two member firms.

The findings revealed complex undisclosed fiduciary roles involving a customer. Lang established two trusts for a long-time customer and was designated to serve as successor trustee. After the customer, a senior, passed away, Lang assumed the role of trustee. While Lang was not a beneficiary of either trust, he received compensation for serving as trustee—making this a compensated outside business activity requiring disclosure and approval.

Although Lang disclosed other outside business activities to his first employing firm, he did not disclose his trustee roles. After the firm discovered these activities during a branch audit, Lang disclosed the trustee roles. However, the firm rejected Lang's outside business request and instructed him to relinquish his trustee roles. Lang failed to comply with this instruction and continued serving as trustee.

Later, the firm discovered that Lang was continuing to serve as trustee despite being instructed to relinquish these roles and began an internal investigation. Lang then resigned from the firm. This pattern—discovery, instruction to cease, continued activity, and resignation—demonstrates knowing violation of firm policies rather than inadvertent non-disclosure.

When Lang associated with a new firm, he was still serving as trustee for one of the trusts. Although Lang disclosed other outside business activities to the new firm, he did not disclose his ongoing trustee role to the new firm until over two years later. Prior to disclosing his trustee roles to either firm, Lang inaccurately indicated on compliance questionnaires that he was not serving as a trustee for non-family members—false attestations that concealed his activities.

The findings also revealed that Lang was appointed and compensated for serving as executor for the same customer's estate. Lang did not disclose this executor role as an outside business activity in writing to either firm. He inaccurately stated in an annual questionnaire to the original firm that he had disclosed all outside activities and was not acting in a fiduciary capacity. After joining the new firm, Lang inaccurately represented that he had disclosed all outside business activities when he had not.

The four-month suspension, in effect from December 15, 2025, through April 14, 2026, along with the $5,000 fine, reflects the seriousness of multiple undisclosed outside business activities involving fiduciary roles, particularly when combined with false compliance attestations and refusal to comply with firm instructions to relinquish the roles.

Investors should exercise caution when financial professionals offer to serve in fiduciary capacities such as trustee or executor, and should verify that such activities have been disclosed to and approved by the professional's firm.