According to FINRA, Rudy Ruben Mejia Jr. was assessed a deferred fine of $10,000 and suspended from association with any FINRA member firm for eight months for participating in undisclosed private securities transactions and maintaining undisclosed outside brokerage accounts.
Mejia co-founded a pooled investment fund with an options trading strategy, along with a management company to serve as the fund's general partner. Mejia personally invested $100,000 in the fund's limited partnership interests. Additionally, seven other investors purchased a total of $738,000 of interests. The investors were friends or family of Mejia or the other co-founder, and none were customers of his firm.
Mejia failed to obtain his firm's approval for either his personal investment or his participation in the private securities transactions involving other investors.
Additionally, Mejia opened outside brokerage accounts for the investment fund and its general partner at another broker-dealer without disclosing these accounts to his firm. He controlled these accounts and had a beneficial interest in them. Mejia executed 304 transactions in these accounts while registered with his firm, without written consent and without notifying the executing firm of his association.
This case illustrates the comprehensive nature of outside activity disclosure requirements. Representatives must disclose not only personal investments but also their involvement in investment vehicles that raise capital from others, as well as any outside accounts they control. The eight-month suspension reflects the multiple violations and the significant amount of capital involved.