Lisa Ann Brumm (also known as Lisa Ann Moon) of Portland Oregon a stockbroker formerly registered with AXA Advisors LLC has been fined $7,500.00 and suspended for six months from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity based upon findings that she provided unsuitable recommendations to customers and made misrepresentations to them concerning annuities. Letter of Acceptance Waiver and Consent No. 2019062286101 (Feb. 3, 2021).
According to the AWC, in December of 2016, a customer had been advised by Brumm to place $400,000.000 into variable annuities and to buy a guaranteed income and death benefit rider for one of those annuities. There was no adequate basis for Brumm to conclude that the customer would receive any benefit from those annuities or riders.
The AWC emphasized that the customer was the age of 28 at the time that they were told by Brumm to buy the annuity. The customer’s tax bracket of 15 percent and their investment horizon presented two additional red flags. FINRA specified that the customer’s investment horizon was too short for them to obtain a benefit for tax deferral since taking distributions at age 43 would subject the customer to tax penalties.
The guaranteed income rider did not make sense as the customer did not have any goal of generating guaranteed income. FINRA also indicated that the death benefit rider was unreasonable as the customer did not have any dependents or other needs for that benefit. FINRA determined that Brumm’s unsuitable investment recommendations were violative of FINRA Rules 2010, 2111 and 2330.
FINRA indicated that Brumm also borrowed money from a customer. On April 11, 2017, Brumm and a customer entered into an agreement for Brumm to borrow $40,000.00. The terms of repayment were provided in a promissory note. The AWC revealed that the stockbroker was prohibited from borrowing from customers at that time. FINRA determined that Brumm’s unauthorized loan arrangement violated FINRA Rules 2010 and 3240.
The regulator also revealed that false information was provided to the customer by Brumm concerning their variable annuity. In January of 2017, Brumm had been contacted by the customer for purposes of withdrawing $22,000 from the annuity. At this point, the customer was receiving ongoing payments of $561.00 from a variable annuity. In February of 2017, the customer was led to believe from Brumm that the withdrawal would result in the customer still receiving $290 per month in guaranteed income. By following Brumm’s advice, the customer stopped receiving monthly payments under the annuity and had also experienced fees and charges for making the withdrawal. FINRA determined that Brumm’s negligent misrepresentations constituted the violation of FINRA Rule 2010.
FINRA Public Disclosure reveals that Brumm has been identified in two customer initiated investment related disputes concerning allegations of her misconduct during the period that she was associated with AXA Advisors. On August 2, 2017, a customer filed an investment related complaint concerning Brumm’s conduct where the customer requested compensatory damages founded on accusations that misrepresentations had been made to the customer concerning a variable annuity.
Brumm has also been referenced in a customer initiated investment related written complaint on March 20, 2019 in which the customer sought $34,415.00 in damages supported by allegations that the customer was sold an unsuitable variable annuity from Brumm during the time that she was associated with AXA Advisors.
Brumm’s registration with AXA Advisors was terminated on May 10, 2017. Between April 28, 2017 and December 31, 2020, she was registered with Woodbury Financial Services Inc.
