FINRA Bars Matthew R Logan for Using Imposter to Cheat on Regulatory Exams and Lying to Firm (Appeal Pending in Federal Court)
According to FINRA, Matthew R Logan (CRD #5366984) of Braintree, Massachusetts, was barred from associating with any FINRA member firm in all capacities. The SEC affirmed the National Adjudicatory Council (NAC) decision, and the bar is in effect as of April 23, 2024, even though Logan has appealed the matter to the United States Court of Appeals. This action arises from FINRA Case #2019063570502.
Logan was found in violation of FINRA rules for using an imposter -- specifically, his office administrative assistant -- to complete FINRA Regulatory Element continuing education courses on his behalf. These courses included critical training modules on ethics and anti-money laundering (AML) compliance. In addition to the cheating scheme, Logan was found to have lied about his misconduct to his firm's parent company during the firm's investigation into the matter.
The Regulatory Element is a mandatory continuing education requirement for all registered representatives. It is designed to ensure that brokers maintain current knowledge of securities regulations, ethical standards, and compliance obligations. The courses cover topics that are directly relevant to investor protection, including suitability requirements, ethical obligations, and AML procedures. By having someone else complete these courses, Logan demonstrated a fundamental disregard for the regulatory framework designed to protect investors.
The use of an imposter to complete compliance training is particularly concerning because it means the registered representative may lack essential knowledge needed to serve clients properly and detect suspicious activities. AML training, for example, is critical for identifying and reporting potential money laundering or terrorist financing activities. A broker who has not genuinely completed this training may fail to recognize red flags that could indicate illegal activity in client accounts.
Logan's subsequent dishonesty during the firm's internal investigation compounded the seriousness of the violations. Providing false information to a firm during an internal review undermines the compliance process and demonstrates a pattern of deception.
Notably, while Logan has appealed to the U.S. Court of Appeals, the bar remains in effect during the pendency of the appeal. This means Logan cannot work in the securities industry while the court considers his case. The SEC's affirmation of the NAC decision reflects a thorough multi-level review of the evidence and sanctions.
Investors should understand that continuing education requirements exist to ensure their brokers are qualified and knowledgeable. FINRA BrokerCheck can provide information about a broker's qualifications, examination history, and disciplinary record.