Guillermo William Valladolid, of La Jolla, California, a stockbroker formerly employed with Morgan Stanley, has been barred from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity by consenting to findings that he failed to comply with FINRA in an investigation into allegations of Valladolid selling away from Morgan Stanley. Letter of Acceptance, Waiver and Consent, No. 2017054997501 (Jan. 12, 2018).
According to the AWC, Valladolid was fired by Morgan Stanley on July 24, 2017, based upon accusations that he inappropriately engaged in outside business activities while employed with the firm. FINRA subsequently launched an investigation into Valladolid’s activities. The AWC stated that on August 8, 2017, FINRA sent Valladolid a letter according to Rule 8210, where Valladolid was asked to provide information and documentation to FINRA relating to his possible outside business activities and private securities transactions.
The AWC stated that the letter called upon Valladolid to respond by August 22, 2017, and his failure to respond could result in FINRA’s imposition of sanctions against him. Despite FINRA’s warning, Valladolid evidently failed to provide a written statement and documentation. Subsequently, on September 18, 2017, counsel for Valladolid informed FINRA that Valladolid would not be providing any information or documentation requested by FINRA. Then, on October 12, 2017, counsel for Valladolid informed FINRA that Valladolid would not be cooperating in any manner in FINRA’s investigation into his alleged violative conduct. FINRA found Valladolid’s refusal to cooperate to be violative of FINRA Rules 2010 and 8210.
FINRA Public Disclosure confirms that on April 10, 2015, Valladolid was terminated from his only other broker-dealer employer, Merrill Lynch, Pierce, Fenner & Smith Incorporated, based on accusations that he failed to inform the firm about a customer complaint. Apparently, Merrill Lynch concluded that Valladolid violated industry standards of conduct, as well as the regulations and statutes governing the securities industry.
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