According to FINRA, Jeremiah Roman was assessed a deferred fine of $5,000 and suspended from association with any FINRA member in all capacities for four months for personally investing $44,100 in eight agreements with a merchant cash advance company and soliciting a firm customer to invest $150,000, without providing prior written notice to or obtaining written approval from his member firm.

Roman's agreements with the company provided that he would receive a monthly payment in a specified amount in return for each investment. Roman introduced the customer to the company, provided marketing materials, and facilitated the exchange of information between the customer and the company. He did not disclose his participation in the customer's investments to his firm, even though he was advised by its compliance hotline to disclose his merchant cash advance company-related activities for review.

Furthermore, Roman falsely attested on an annual compliance questionnaire that he had not participated in any private securities transactions that had not been approved by the firm. This case demonstrates the risks of merchant cash advance investments and the importance of firm supervision. When representatives engage in private securities transactions without firm approval, customers lose the protection of firm due diligence and oversight.