Ronald Dunn, a registered representative with Pruco Securities, LLC, was permanently barred by from associating with any Financial Industry Regulatory Authority (FINRA) registered firm after consenting to findings that he had failed to cooperate in an investigation in connection with Dunn’s alleged conversion of customer funds. Letter of Acceptance, Waiver, and Consent, No. 2014042095201 (Apr. 9, 2015).
According to the Letter of Acceptance, Waiver, and Consent, FINRA was investigating Dunn after his employer, on July 28, 2014, filed an amended Form U5 which had reported that Dunn was subject to review for accepting funds from a firm client’s policy, where he deposited such funds into his own personal bank account and not repaid funds to the client with interest as he agreed to do. FINRA was concerned with whether Dunn converted the funds for his personal gain.
The AWC indicated that on February 6, 2015, the Department of Enforcement had sent him a request, per Rule 8210, to appear for testimony. Dunn reportedly failed to appear based on such request as well as an additional one. Dunn, according to the AWC, acknowledged with FINRA staff in a phone call on March 30, 2015, that he received FINRA’s requests, yet he failed to comply. As a result, Dunn consented to findings that he violated Rule 8210 and 2010, and was permanently barred by FINRA as a result.
FINRA registered representatives like Dunn who do not cooperate with FINRA’s investigations often face a permanent bar from practicing in the securities industry as such lack of cooperation violates FINRA’s Rule 8210 – requiring that no member or person shall fail to provide information or testimony or permit an inspection and copying of books, records, or accounts pursuant to the rule. FINRA typically accompanies a Rule 8210 violation with a Rule 2010 violation when individuals, according to FINRA, do not appear to observe high standards for commercial honor and just and equitable principles of trade.
Public disclosure records reveal that Dunn has been subject to four disclosure events. On November 21, 2013, he was discharged by Pruco Securities, LLC, after accepting monies from a client’s policy, depositing them in his personal bank account, and not fully repaying the funds (his firm also noted he failed to report 2 unsatisfied liens). On May 1, 2014, Dunn consented to fines and suspension from FINRA after arranging to borrow $40,000 from a customer without authority.
On June 25, 2014, Dunn became subject to a customer dispute (pending) where a client alleged that in 2012, Dunn commingled the client’s funds into his own personal bank accounts. Subsequently, the client received two promissory notes from Dunn guaranteeing a return on purported investments, where Dunn failed to comply with the terms of such promissory notes.
Firms and individuals, not surprisingly, are prohibited from unauthorized use of customer funds, borrowing of a customer’s securities or funds, forgery, non-disclosures or misstatements of material facts, and various deceptions and manipulations. Such conduct can also be found to violate criminal and other civil laws, and be subject to sanction from the federal and state government bodies.
Securities brokerage firms have a duty to supervise their brokers and the sales practices of their brokers, and to review customer statements for, among other things, evidence of suitability, unauthorized trading, or excessive activity.
Guiliano Law Group
If you have been the victim of securities fraud and you have a complaint, you should consult with an attorney. The practice of Nicholas J. Guiliano, Esquire, and The Guiliano Law Group, P.C., is limited to the representation of investors in claims for fraud in connection with the sale of securities, the sale or recommendation of excessively risky or unsuitable securities, breach of fiduciary duty, and the failure to supervise. We accept representation on a contingent fee basis, meaning there is no cost unless we make a recovery for you, and there is never any charge for a consultation or an evaluation of your claim. For more information contact us at (877) SEC-ATTY.
