Leslie Koonce, of Menlo Park, California, a stockbroker formerly registered with LPL Financial LLC, has been barred from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity based upon consenting to findings that he obstructed a FINRA investigation into allegations that he sold away from his firm and falsified information about his activities when questioned by FINRA personnel. Letter of Acceptance, Waiver and Consent, No. 2015048088401 (Dec. 14, 2017).
According to the AWC, Koonce participated in private securities transactions from January of 2012 to March of 2015. Particularly, from January of 2012 to June of 2012, a minimum of thirty investors, some of whom included customers of LPL Financial, had been solicited by Koonce to make investments in a private company’s convertible promissory notes.
Apparently, prospective investors had been sent information relating to the private company by Koonce through his LPL Financial e-mail address. Koonce reportedly made the arrangements for meetings between the prospective investors and the private company’s representatives in order to procure information relating to the investment. He also helped facilitate the transfer of LPL Financial customers’ funds to purchase a total of $175,000.00 worth of the convertible promissory notes. Koonce also evidently made a personal investment in the private company, contributing $50,000.00 to obtain convertible promissory notes. The AWC also revealed that in March of 2015, Koonce used another $50,000.00 of his own money to buy a second private company’s stock shares.
The AWC stated that LPL Financial was never made aware of Koonce’s involvement in the private securities transactions prior to him engaging in them. Consequently, FINRA found that Koonce’s conduct was violative of FINRA Rule 2010 and NASD Rule 3040.
Moreover, the AWC stated that compliance questionnaires had been completed by Koonce in May of 2012 and November of 2012 in accordance with LPL Financial’s requirements. Evidently,
Koonce responded to the questionnaires, in which he attested to never having sold away from the firm. FINRA found that Koonce’s false denials of participating in private securities transactions was conduct violative of FINRA Rule 2010.
Thereafter, FINRA launched an investigation into Koonce’s purported misconduct, requesting that Koonce provide information and documentation relating to his activities. The AWC stated that Koonce made false statements to FINRA in response, where he claimed that he had not assisted LPL Financial customers in effecting transactions away from the firm. Additionally, he denied having made personal investments in the second private company in March of 2015 even though he made a $50,000.00 investment. Consequently, FINRA concluded that Koonce’s failure to be forthcoming in the investigation was violative of FINRA Rules 2010 and 8210.
FINRA Public Disclosure reveals that Koonce has been subject of three additional regulatory infractions concerning his misconduct. Particularly, he has been fined $5,000.00 and suspended from associating with any National Association of Securities Dealers (NASD) member in any capacity based upon consenting to findings that while associated with Hornor, Townsend & Kent, he signed a customer’s name on variable universal life insurance policy account documentation to effect the transfer of a retirement account. Case No. C01990015 (Aug. 19, 1999). Koonce was also fired by Hornor, Townsend & Kent as a result.
Koonce was fired from LPL Financial LLC on November 18, 2015, based upon allegations that he violated the firm’s policies by facilitating securities transactions away from the firm. Prior to having been barred by FINRA, he was associated with EK Riley Investments, LLC, between December 9, 2015 and November 30, 2017.
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