Caffe Aldo Lamberti is one of my favorite restaurants in all of South Jersey.
So my wife and I were rather excited when we received a “Special Invitation” in the mail for a “Complimentary Evening of Fine Dining” at our favorite restaurant, while at the same time we would learn about the “latest strategies to lower our tax liability, protect our assets, and create income we can’t outlive — regardless of market conditions.”
All that plus pizza bread. Could it all be true? 
So I decided to check it out.
It appears that our special invitation to a night of fine dining is courtesy of Woloshin Investment Management LLC. The Invitation says Woloshin Investment Management “is not affiliated or endorsed by the Social Security Administration or any Government Entity.” I guess that is good, maybe. Maybe not. I do remember a few decades ago that the government was handing out aged Cheddar cheese.
But who is Woloshin Investment Management? So I decided to check their website. Woloshin Investment Management does not appear to be a securities broker-dealer or registered as a member of the Financial Industry Regulatory Authority. Woloshin Investment Management appears to be a Registered Investment Advisor or RIA. To become a Registered Investment Advisor, apparently, at least according to the SEC’s website, you have to fill out a form, Form ADV, and within 45 days after you file your Form ADV registration application, the SEC “must grant your registration or begin proceedings to deny it.” No tests to take, no insurance required. Just send in your Form. Seems rather simple. Certainly easier than getting that Minister’s License I always wanted to perform weekend weddings (which also includes the distribution of free food if you get invited to the reception).
But anyway, who is Woloshin Investment Management LLC? Woloshin Investment Management “LLC” is a Limited Liability Company, and the eponym of its founder and its Managing Member, Michael Woloshin. FINRA Public Disclosure reveals the existence of a once registered Michael Allan Woloshin of Medford, New Jersey. Woloshin Investment Management is also in Medford, New Jersey.
However, that Michael Allan Woloshin, appears to have been associated with eight securities broker-dealers, three of whom have been expelled by regulators or are otherwise defunct. He also appears to have been subject to two (2) regulatory actions, seven (7) customer initiated investment related complaints and/or arbitration proceedings alleging sales practice violations, and seeking damages in excess of $5,000.
That Michael Allan Woloshin, according to FINRA Public Disclosure, appears to have been terminated or “Discharged” by his former employer, Summit Brokerage Services Inc., on April 21, 2016, because “The Firm determined that the Woloshin Branch submitted two Fixed Index Annuity applications to the issuing insurance company prior to the approval of those applications by the Firm.”
We do not know Michael Allan Woloshin, but certainly anyone that is willing to drive from Medord to Cherry Hill to buy a bunch of people he does not know a free diner, or an “evening of fine dining” at Caffe Aldo Lamberti cannot be all that bad.
But we do know about annuity schemes. Annuity schemes are not the “latest strategies” but are as old as govenment cheese. We also know that anyone promising to “lower your tax liability, protect your assets, and create income you can’t outlive — regardless of market conditions” is probably hawking annuities. Why not. Index Option Annuities are not even securities, but are insurance products so you do not even need a license. Better yet, the commissions based upon the sale of these products range from 7% to 13% of every dollar invested. Not bad when you get fired from your old job, and maybe cannot otherwise find decent work. Besides, Aldo’s ain’t cheap.
We also know that FINRA and other regulators keep warning investors and are particularly concerned with the use of aggressive or “misleading sales tactics aimed at seniors, particularly the use of ‘free lunch’ seminars, where “[a]mong the most common practices were inaccurate or exaggerated claims regarding the safety, liquidity or expected returns of the investment or strategy being touted.” Notice to Members 07-43
But that is only “lunch,” and this is “dinner” at Aldos.
Nicholas J. Guiliano has over twenty years experience representing investors before the Financial Industry Regulatory Authority, the New York Stock Exchange and before the National Association of Securities Dealers, Office of Dispute Resolution. Over the last twenty years, Mr. Guiliano has represented more than a thousand investors from all across the United States and from several foreign countries, in claims against stockbroker and broker-dealers for fraud, breach of fiduciary duty, churning or excessive trading, the sale of unsuitable investments, the sale of defective investments, the sale of unregistered securities, and the failure to supervise. He is frequently quoted in the national media on securities and investment related issues, most recently on National Public Radio. He offers his services on purely a contingent fee basis, and is also a member of Public Investors Arbitration Bar Association.
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