Cody Michael Keller, of Mechanicsburg, Pennsylvania, a stockbroker registered with Northwestern Mutual Investment Services LLC and later with MML Investors Services LLC, has been barred from associating with any Financial Industry Regulatory Authority (FINRA) member in all capacities because Keller failed to provide documents and information requested in an investigation into alleged unauthorized payments to a customer, undisclosed outside business activities, and Keller’s failure to update regulatory disclosures. Letter of Acceptance, Waiver, and Consent No. 2023079675401 (March 19, 2025).
On August 30, 2023, Northwestern Mutual filed a Form U5 reporting that Keller had been permitted to resign following the discovery that he paid a customer from his personal bank account, in what appeared to be an attempt to avoid a formal customer complaint. The securities broker dealer also noted that Keller had engaged in an outside business activity without disclosure or approval and had not provided accurate responses when questioned about his conduct.
On August 17, 2023, Keller became registered with MML Investors Services LLC. However, his employment there was short-lived. On October 14, 2024, MML filed a Form U5 stating that it had terminated Keller for failing to disclose a regulatory action with the state of Pennsylvania on his Form U4.
On February 13, 2025, as part of an investigation into his terminations from both Northwestern Mutual and MML Investors Services, FINRA issued a request under Rule 8210 for documents and information. Keller, through his lawyer, acknowledged receipt of the request but declined to provide the requested materials. His refusal was confirmed by his attorney’s email to FINRA on February 20, 2025, a subsequent phone call on February 27.
FINRA determined that Keller violated Rule 8210 by failing to comply with its request for information and documentation. This refusal also constituted a violation of Rule 2010.
Prior to this, on May 29, 2024, Pennsylvania Insurance Department issued a Consent Order in a disciplinary action against Keller. That order concluded that Keller had misrepresented whether customer payments were going toward insurance policies or into an IRA. Additionally, he paid customers $1,000 from his personal bank account when they requested hardship withdrawals from what they believed to be Roth IRA accounts. Keller consented to pay a fine of $1,000 as part of resolving the matter.
FINRA Public Disclosure also shows that on November 3, 2023, a customer filed an investment related complaint involving Keller’s conduct in which the customer requested $5,410.00 in damages based upon allegations that Keller recommended life insurance products that poorly performed when Keller was associated with Northwestern Mutual Investment Services LLC.
Keller was associated with Northwestern Mutual Investment Services LLC in Mechanicsburg, Pennsylvania from March 17, 2017 to August 30, 2023. He was associated with MML Investors Services LLC in Mechanicsburg, Pennsylvania from August 17, 2023 to October 14, 2024.
