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Harold Francis Couglar of San Diego California a stockbroker formerly registered with Montage Securities LLC has been barred from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity based upon consenting to findings that he (1) failed to report his discretionary trading of customer accounts held away from Montage Securities and (2) engaged in undisclosed outside business activities. Letter of Acceptance Waiver and Consent No. 2017052715901 (May 21, 2018).

According to the AWC, while Couglar was associated with Linsco/Private Ledger Corp., CBIZ Financial Solutions, Inc. and Montage Securities, he exercised discretion in fifty investors’ accounts housed away from Couglar’s employing brokerage firms, where Couglar purchased and sold bonds and common stock in the investors’ accounts. The AWC revealed that between March 28, 2012 and December 13, 2016, during the time Couglar was employed by Montage Securities, he was compensated $102,956.00 from the investors which owned accounts away from Montage Securities. Evidently, throughout that period, at least two thousand eight hundred trades were placed in the investors’ accounts, with purchases and sales totaling at least $30,000,000.00.

The AWC revealed that Couglar’s employing firms were never notified about the outside accounts that Couglar traded in, and he failed to inform the brokerage firms housing the outside accounts about his association with his employing firms. Moreover, during the time that Couglar traded in those outside accounts, Couglar reportedly falsely represented in five of Montage’s compliance questionnaires that he did not exercise discretion in outside accounts. Consequently, FINRA found that Couglar’s conduct was violative of FINRA Rule 2010 and National Association of Securities Dealers (NASD) Rules 2110 and 3050(c).

The AWC further detailed that between March of 2012 and December of 2016, Couglar provided eighteen individuals with tax preparation services in return for him being compensated $27,255.00. Couglar evidently failed to be forthcoming to Montage Securities about his outside business activities within the compliance questionnaires that he completed. FINRA concluded that Couglar’s activities in that regard were violative of FINRA Rules 2010 and 3270.

On December 13, 2016, Couglar was discharged by Montage Securities founded on allegations that he maintained an interested party status on outside investment accounts in violation of the firm’s policies.

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