Christopher Taylor Harpin, of Essex, Connecticut, a stockbroker registered with Lincoln Financial Securities Corporation (now Osaic FS Inc.), has been fined $5,000.00 and suspended for two months from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity because Harpin mismarked trades and caused the securities broker dealer to maintain inaccurate records about his trading. Letter of Acceptance, Waiver, and Consent No. 2021071460101 (April 2, 2025).
According to the AWC, FINRA’s regulatory action against Harpin originated from its review of an arbitration filed against Harpin in April 2021. FINRA Arbitration No. 21-00905 (May 23, 2023).
FINRA found that between August 2018 and April 2021, while registered through Lincoln Financial Securities Corporation, Harpin was responsible for at least 638 purchases of high-yield bonds in 53 customer accounts that were inaccurately reported as unsolicited orders. FINRA sated that Harpin had solicited these transactions. Under FINRA Rules, the duty of suitability only applies to “recommendations.” Stockbrokers erroneously believe that by mismarking an actual recommendation, as “unsolicited,” meaning that the customer purchased these securities on their own intiative, the broker can escape liability, and also escape detection by supervisory personel. However, most firms have unsolicited trade reports which will show the existence of other customers purchasing these same securities, the only common nexus being the recommendation of the broker. Firms will also send letters to customer to confirm that the transactions were actually unsolicted and not based upon the recommendation of the broker. Customers, however, often fail to respond or return these forms.
This misclassification of trade orders violated FINRA Rule 4511, which requires the accurate maintenance of records at the securities broker dealer. The trades also breached the Securities Exchange Act’s requirements for firms to document the terms of each brokerage order—including whether the trade was solicited. The AWC stated that Harpin’s actions continued even after Lincoln Financial Securities Corporation warned him that soliciting high-yield bond trades was not permitted. As a result of these inaccuracies, Harpin also violated FINRA Rule 2010.
FINRA Public Disclosure also shows that on December 15, 2003, a customer filed an investment related complaint involving Harpin’s conduct in which the customer requested $400,000.00 in damages based upon allegations that Harpin failed to execute a stop loss order when Harpin was associated with Samuel A. Ramirez Co. Inc. The complaint was closed without further action taken by the customer.
Harpin was also referenced in a customer initiated investment related FINRA securities arbitration claim that was settled for $590,000.00 in damages based upon allegations that Harpin recommended municipal and corporate bonds without a trustee’s knowledge when Harpin was associated with Lincoln Financial Securities Corporation. FINRA Arbitration No. 21-00905 (May 23, 2023).
Harpin was associated with Lincoln Financial Securities Corporation in Essex, Connecticut from December 2, 2016 to April 26, 2021. Harpin has been associated with Cambridge Investment Research Inc. in Essex, Connecticut since April 23, 2021.
