According to FINRA, Ronald Harland Berg was barred from association with any FINRA member in all capacities for refusing to provide information and documents requested by FINRA.

FINRA's examination focused on Berg's recommendations to multiple senior customers to invest in private offerings and his involvement with customer trusts. Initially, Berg provided a partial but incomplete response that did not substantially comply with FINRA's request. The information and documents he failed to provide were material to the examination. Ultimately, Berg refused to provide additional information and documents.

The examination concerns are significant. Recommendations to senior customers to invest in private offerings raise suitability concerns because private offerings are typically illiquid, high-risk investments that may not be appropriate for seniors who need to preserve capital and maintain liquidity for living expenses. Private offerings also typically lack the disclosure and regulatory protections of registered public offerings, making them riskier for unsophisticated investors.

Berg's involvement with customer trusts is also concerning. Registered representatives should generally not serve as trustees or have other roles in customer trusts because these arrangements create conflicts of interest and opportunities for self-dealing. A broker who controls a customer's trust could make investment decisions that benefit the broker through commissions rather than decisions that are in the customer's best interest.

Berg's initial partial response followed by ultimate refusal to cooperate suggests an attempt to appear cooperative while withholding material information. The fact that he provided some information but not everything requested may indicate that he was trying to control what FINRA could learn about his activities. When FINRA persisted in requesting complete information, Berg refused entirely.

The bar sanction removes Berg from the industry, protecting senior investors and others from someone who recommended potentially unsuitable investments to vulnerable customers and then refused to cooperate when regulators sought to examine his conduct.

Investors, particularly seniors, should be very cautious about private offering investments and should never allow their broker to serve as trustee or have any control over their trust. These arrangements create conflicts of interest and opportunities for abuse.