Brad Curtis Brooks of Plano, Texas, a stockbroker registered with Titan Securities, has been fined $15,000.00 and suspended for three months from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity because he made negligent misrepresentations and omissions to customers concerning private placements during the time that he was associated with Titan Securities. Letter of Acceptance, Waiver, and Consent No. 2019062479102 (January 16, 2024).
FINRA’s disciplinary action originated from an examination into Titan’s sales of certain private placement offerings managed by Brooks and his business partner. Between January of 2017 and August of 2019, Brooks was found by FINRA to have made omissions and misrepresentations to investors in two private placement securities offerings named Evolution RE Bishop’s Lodge LP (Bishop’s Lodge) and Evolution RE Hall Arts Hotel LP (Hall Arts), both controlled by Brooks.
FINRA stated that Brooks failed to inform investors in Hall Arts about the transfer of funds to Bishop’s Lodge, which was not an allowable use of investor proceeds according to a private placement memoranda (PPM). This led to misleading representations about the use of funds. Furthermore, Brooks allowed the value of these transfers to be misrepresented in other PPMs for Bishop’s Lodge, overstating the capital raised by the partnership. Therefore, FINRA alleged that he violated FINRA Rule 2010.
FINRA Public Disclosure shows that Brooks was the subject of a customer initiated investment related FINRA securities arbitration claim in which the customer was awarded $65,000.00 in compensatory damages because Brooks and Everen Securities Inc. were held liable for sales practice violations. FINRA Arbitration No. 98-03452 (August 23, 2001). The Statement of Claim alleged misrepresentations and omissions of material fact, breach of contract, and negligence in connection with the sale of options during the time that Brooks was associated with Everen Securities Inc.
On July 24, 2018, a customer initiated investment related FINRA securities arbitration claim involving Brooks’ conduct was settled for $9,850.00 in damages based upon allegations that Brooks failed to supervise certain representatives in connection with the sale of direct investments during the period that Brooks was associated with Titan Securities. FINRA Arbitration No. 18-02577.
Brooks was also the subject of a customer initiated investment related FINRA securities arbitration claim in which the customer received $118,000.00 in compensatory damages. FINRA Arbitration No. 17-02747 (March 17, 2019). The Statement of Claim alleged that Brooks failed to supervise certain representatives in connection with the sale of alternative investments during the time that Brooks was associated with Titan Securities.
Brooks was associated with Titan Securities in Plano, Texas, from October 7, 2005, to July 3, 2023.