Andres F. Talero, of Miami, Florida, a stockbroker with Invex, Inc., was fined $50,000.00 and suspended for two years from associating with any Financial Industry Regulatory Authority (FINRA) member firm in any capacity after consenting to findings that he engaged in outside business activities and private securities transactions.
According to the AWC, in June 29, 2011, while Talero was associated with Invex, he and a business partner created BVI Entity. BVI Entity was apparently a subsidiary of an entity which Talero had previously reported to Invex as an outside business activity when hired. Talero reportedly owned half of BVI, and such ownership was not within the scope of his Invex employment. The AWC stated that Talero neither notified Invex of his involvement with BVI, nor indicated to Invex information regarding his ownership. Invex reportedly did not approve BVI as an outside business activity.
The AWC subsequently stated that in September 2013, BVI became director of a company, New Zealand Entity. Talero, through BVI, apparently directed affairs for New Zealand as a signatory. Yet, Talero did not provide his firm with written notice regarding his involvement with New Zealand. Invex, according to the AWC, did not approve of Talero’s involvement in this regard, which was outside the scope of the firm. FINRA found that Talero’s conduct of engaging in unauthorized outside business activities was violative of FINRA Rules 2010 and 3270.
The AWC also stated that Talero engaged in unauthorized private securities transactions. Specifically, Talero engaged in three private securities transactions in Country A from July 2011 through April 2012. The AWC stated that Talero’s participation was designed to assist a Spain based entity in the movement of funds from a Country A subsidiary back to the entity in Spain. The transactions reportedly relied upon Country A’s currency to be utilized in purchasing greater than $250,000,000.00 worth of U.S. Treasury Bills.
The AWC stated that Talero’s participation in the private securities transactions, which he received $2,000,000.00 for, included structuring the transactions, and facilitating the execution of such. The transactions; however, were outside the auspices of Invex, and his firm never received any written notification regarding Talero’s participation prior to him engaging in such transactions. Invex reportedly did not approve Talero’s participation in this regard.
The AWC further reported that from September 2013 through March 2014, Talero engaged in private securities transactions within Country B with respect to two of Country B’s clients. In this case, $4,000,000.00 worth of invoices were sold to purchase Country B government bonds. The AWC stated that Talero received $125,000.00 in compensation for participating in structuring and facilitation of these transactions. Like Talero’s other business activities, his participation in this regard occurred outside the auspices of Invex. Apparently, Invex neither knew of or approved of the transactions. FINRA found that Talero’s conduct was violative of FINRA Rule 2010 and NASD Rule 3040.
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