Neemit Mukesh Shah of Glen Allen Virginia a stockbroker formerly employed by NYLife Securities LLC has been fined $5,000.00 and suspended for six months from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity founded on findings that Shah engaged in private securities transactions during the period that he was associated with NYLife Securities. Letter of Acceptance Waiver and Consent No. 2020065315701 (Oct. 6, 2020).
According to the AWC, from March of 2016 to April of 2016, investors had been advised by Shah to invest in Future Income Payments LLC (FIP) which was purportedly a structured cash flow investment. FINRA stated that Future Income Payments would buy pensions at a discounted value and then effect the sale of a pension stream to a customer. Customers had been promised a seven or eight percent return from Future Income Payments.
The AWC stated that $408,000.00 worth of Future Income Payments purchase agreements had been sold by Shah to at least two NYLife customers. Those investors’ purchases produced $8,160.00 in commissions for the stockbroker.
The regulator indicated that when Shah was associated with NYLife, he was prohibited from effecting private securities transactions without going through an approval process. Shah was instructed under company policy to furnish written notification of any private securities transactions. He was also required under company policy to obtain permission before taking part in those transactions.
NYLife was not provided notification of Shah’s involvement in Future Income Payments transactions. The lack of notice meant that the stockbroker was not authorized to effect any FIP sales. The securities broker dealer was also falsely told by Shah that he did not sell away or engage in private securities transactions. FINRA found that Shah’s conduct was violative of FINRA Rules 2010 and 3280.
The AWC stated that Future Income Payments owed $300,000,000.00 in investor payments when the company stopped doing business in April of 2018. The company and its owner Scott A. Kohn have been charged with conspiracy to engage in wire fraud and mail fraud in regard to its operations of FIP.
Shah was also registered with MML Investors Services between December 19, 2016 and November 16, 2018 and then employed by Northwestern Mutual Investment Services between September 5, 2019 and May 19, 2020.