According to FINRA, Todd Michael Seymour was assessed a deferred fine of $5,000 and suspended for two months in all capacities for failing to notify his firms about the full nature of his participation in an outside business activity.
Before becoming associated with any FINRA member, Seymour provided tax preparation and trust administration services through his wife's tax and estate business. He also served as co-trustee of a trust. The trust and its beneficiaries later became his customers.
When Seymour associated with his first firm and requested approval to continue working for his wife's business, the firm approved the outside business activity but prohibited him from continuing to serve as co-trustee. When he later joined a second firm, he again requested approval to work for his wife's business but did not disclose that he provided trust administration services, including performing co-trustee duties. His written request described his responsibilities merely as tax preparation. The firm approved the outside business activity but prohibited him from serving as a trustee or maintaining bill-paying authority over any third-party bank account.
Seymour exceeded the scope of his approved outside business activity at both firms. At the direction of the remaining co-successor trustee, he continued performing co-trustee duties despite both firms prohibiting him from serving as a trustee. He also violated the second firm's prohibition against bill-paying authority by using his check-writing authority for the trust's bank account to issue checks, including to compensate himself for services.
Seymour submitted compliance questionnaires to one firm falsely attesting he had not participated in undisclosed outside business activities.
The two-month suspension holds Seymour accountable for deliberately concealing the full scope of his outside business activity and exceeding approved limitations.