According to FINRA, Jeremy Dillon Baldwin was assessed a deferred fine of $7,500 and suspended from association with any FINRA member in all capacities for five months on October 4, 2024.

Baldwin engaged in an outside business activity by acting as an investment advisor for a 401(k) plan without providing prior written notice to his member firm. Baldwin received compensation from the 401(k) sponsor for the services he provided, including facilitating employee enrollment and acting as an intermediary between the sponsor and the 401(k) provider and administrator. Baldwin also falsely attested that he did not have any undisclosed outside business activities on annual firm questionnaires.

Additionally, Baldwin falsified firm records when he completed two annual compliance questionnaires for another representative and submitted them to the firm. Although Baldwin completed and submitted the questionnaires at the representative's request, the representative did not review the questionnaires for accuracy or completeness prior to their submission. Baldwin thus created the false impression that the registered representative had completed the questionnaires.

Outside business activities must be disclosed to firms so they can assess potential conflicts of interest and ensure appropriate supervision. Acting as an investment advisor to a 401(k) plan is exactly the type of activity that creates potential conflicts. Baldwin was presumably advising 401(k) participants about investment options and possibly receiving compensation based on plan assets or participant enrollment. This could create conflicts with his duties to customers at his firm.

The false attestations on annual questionnaires demonstrate active concealment rather than mere oversight. Baldwin knew about the disclosure requirement and deliberately chose to hide his outside business activity from his firm. This prevented the firm from supervising the activity and managing potential conflicts.

The falsification of compliance questionnaires for another representative is a separate serious violation. Compliance questionnaires are critical tools that firms use to identify potential issues and ensure representatives are following rules. When Baldwin completed questionnaires on behalf of another representative, he undermined the entire purpose of the questionnaires and created false records suggesting the other representative had completed them.

Even though the other representative requested Baldwin's assistance, that does not excuse the violation. Each representative is responsible for personally completing their own compliance questionnaires and cannot delegate this responsibility to others. The fact that the other representative didn't even review the questionnaires before submission shows a complete disregard for the compliance process.

For investors, this case illustrates multiple compliance failures involving undisclosed activities, false attestations, and falsified records. These violations demonstrate a pattern of disregarding rules and creating false documentation. Investors should be concerned about working with someone who has shown such a willingness to circumvent compliance requirements.

The five-month suspension from October 7, 2024, through March 6, 2025, reflects the seriousness of Baldwin's multiple violations. The deferred fine acknowledges his financial circumstances while still imposing a monetary penalty.