Tobin J. Senefeld, of Carmel, Indiana, a stockbroker with Pin Financial, LLC, was permanently barred from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity after consenting to findings that he obstructed a FINRA investigation into allegations that Senefeld engaged in a Ponzi scheme. Letter of Acceptance, Waiver and Consent, No. 2015045728801 (Oct. 11, 2016).
According to the AWC, Senefeld was sent a letter from FINRA personnel on August 12, 2016, per FINRA’s Rule 8210, in which Senefeld was asked to provide recorded testimony in connection with FINRA’s investigation into allegations that Senefeld engaged in a Ponzi scheme. Apparently, FINRA’s personnel received a response from Senefeld’s counsel, in which Senefeld acknowledged FINRA’s request to provide testimony but stated that he would not be providing such at any point. FINRA found that Senefeld’s conduct was violative of FINRA Rules 2010 and 8210.
FINRA’s barring of Senefeld came after the Securities and Exchange Commission alleged in a Complaint that Tobin concocted a fraudulent scheme that involved offerings of farm loans. SEC Litigation Release 23246(Apr. 24, 2015). The SEC’s Complaint alleged that $15,000,000.00 was accumulated from eighty investors in the scheme, after representations were made to the investors that monies would be utilized to provide farmers with operating loans.
Apparently, a substantial portion of the funds were utilized to pay off debts incurred by the farmers per other prior loan offerings. Senefeld, along with the investment advisor’s president and another representative, was alleged to have provided investors of previous offerings with millions of dollars, while raking in (unbeknownst to customers) interest rate spread and other fees exceeding $800,000.00. Tobin was alleged by the SEC to have violated Securities Exchange Commission Section 10(b), SEC Rule 10b-5, as well as Securities Exchange Act Section 17(a).
The AWC stated that Senefeld has been previously disciplined on a number of occasions. Particularly, Senefeld was fined $5,000.00 and suspended by FINRA after consenting to findings that he failed to supervise a registered representative who made unsuitable investment recommendations to a firm customer. Letter of Acceptance, Waiver and Consent, No. C11990009 (Mar. 9, 1999). FINRA found that Senefeld’s failure to supervise the registered representative led to the customer’s account being excessively traded. Senefeld apparently did not take reasonable steps to prevent the customer from suffering from the registered representative’s conduct. FINRA found that Senefeld’s conduct in this regard as violative of NASD Rules 3010 and 2010 as a result.
Senefeld was subsequently fined $25,000.00 by the Securities and Exchange Commission and suspended for twelve months from associating with any broker dealer per an SEC Order which contained findings that Senefeld committed free-riding. In the Matter of H.J. Meyers & Co., Inc., and Tobin J. Senefeld, No. 3-9754, Exchange Act Rel. No. 41579 (June 30, 1999). The SEC Order stated that Senefeld’s conduct was violative of Securities Exchange Commission Section 10(b), SEC Rule 10b-5, as well as Securities Exchange Act Section 17(a).
Since 1994, Senefeld has been associated with eight different broker dealers, four of which have been expelled by securities regulators for violation of federal securities laws or are otherwise defunct.
Guiliano Law Group
Our practice is limited to the representation of investors. We accept representation on a contingent fee basis, meaning there is no cost to you unless we make a recovery for you. There is never any charge for a consultation or an evaluation of your claim. For more information, contact us at (877) SEC-ATTY.
