Paul Joseph Godlewski, a Stockbroker with Allstate Financial Services, LLC, was permanently barred from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity after consenting to findings that he failed to cooperate with a FINRA investigation into allegations that he engaged in unapproved outside business activities and failed to follow his firm’s procedures concerning televised public appearances. Letter of Acceptance, Waiver, and Consent No. 20150441079 (Apr. 1, 2015).Allstate Financial Services, LLC discharged Godlewski on January 9, 2015, as a result of his conduct. FINRA has barred Godlewski from acting as a broker or otherwise associating with firms that sell securities to the public.
According to the AWC, on March 12, 2015, FINRA had requested that Godlewski provide information and documentation, pursuant to Rule 8210, concerning their investigation into his alleged misconduct. Godlewski eventually got in touch with FINRA’s staff on March 16, 2015, where he acknowledged that he received the requests but stated that he would not be cooperating at any point. FINRA found Godlewski’s conduct to be in violation of Rule 8210 and 2010, leading to his permanent bar.
FINRA registered representatives like Godlewski who do not cooperate with FINRA’s investigations often face a permanent bar from practicing in the securities industry as such lack of cooperation violates FINRA’s Rule 8210 – requiring that no member or person shall fail to provide information or testimony or permit an inspection and copying of books, records, or accounts pursuant to the rule. FINRA typically accompanies a Rule 8210 violation with a Rule 2010 violation when individuals, according to FINRA, do not appear to observe high standards for commercial honor and just and equitable principles of trade.
Selling away, also known as private securities transactions or undisclosed outside business activities, occurs when a stockbroker engages or participates in the sale of securities to investors outside of the formal approval of the securities firm with whom they are associated.
As a general matter, stockbrokers are only permitted to engage in the solicitation or sale of investments and investment related products approved by their firm. However, quite frequently, stockbrokers solicit, participate, or directly engage in the sale of typically unregistered securities or investments without the approval and outside of the auspices of their firm. These investments may take on many forms, and may include the recommendation of an outside money manager, or a hedge fund, which may sometimes turn out to be a Ponzi scheme. Sometimes these outside investments may include off-shore securities, insurance trusts, stocks or ownership interests in small businesses, startup ventures, corporate debentures, mortgage notes, private placements, promissory notes, oil & gas interests, real estate partnerships, pre-IPO shares, and a variety of other investments.
Guiliano Law Group
If you have been the victim of securities fraud and you have a complaint, you should consult with an attorney. The practice of Nicholas J. Guiliano, Esquire, and The Guiliano Law Group, P.C., is limited to the representation of investors in claims for fraud in connection with the sale of securities, the sale or recommendation of excessively risky or unsuitable securities, breach of fiduciary duty, and the failure to supervise. We accept representation on a contingent fee basis, meaning there is no cost unless we make a recovery for you, and there is never any charge for a consultation or an evaluation of your claim. For more information contact us at (877) SEC-ATTY.
