Raymond Alexander Thomas of Network 1 Financial Securities has been barred from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity according to a Decision and Order of Offer of Settlement containing findings that Thomas engaged in undisclosed outside business activities while registered with Network 1 Financial Securities. Department of Enforcement v. Raymond A. Thomas Disciplinary Proceeding No. 2017056561101 (Dec. 2, 2020).
According to the Decision, from February of 2014 to September of 2017, Thomas took part in outside business activities including his formation and management of Waverly Capital Group. Network 1 was not made aware of Thomas’s actions with Waverly Capital.
FINRA stated that Thomas was also Waverly Capital’s Chairman and General Manager. He effected agreements on the company’s behalf. One of them included an agreement between Waverly Capital and an international venture capitalist. Thomas also caused Waverly Capital to be involved in real estate acquisitions negotiations involving Nevada-based Nevis Limited Liability Company.
The regulator stated that Thomas was compensated for his Waverly Capital work. Bank accounts were opened up by Thomas in Waverly Capital’s name and he arranged for those who did business with Waverly Capital to wire funds into that account. FINRA found that Thomas’s failure to disclose his outside business activities to Network 1 was violative of FINRA Rules 2010 and 3270.
FINRA also found that Thomas provided misleading or false information so that he could hide his outside business activities. The stockbroker’s branch was examined by FINRA in 2017 at which time he told the regulator that he was not involved in any outside activities. He also neglected to disclose all banks which he controlled as a signatory. This includes the Waverly Capital bank account that he accessed to withdrawal approximately $100,00.00 in funds. Thomas also testified falsely as to his involvement with Waverly Capital. The stockbroker claimed that he did not create Waverly Capital and that he did not have authority over its bank accounts. Thomas’s conduct was violative of FINRA Rules 2010 and 8210.
Thomas has been identified in two customer initiated investment related disputes containing accusations of his misconduct while registered with European Community Capital Ltd. and First Montauk Securities Corp. FINRA Public Disclosure reveals that a customer filed an investment related complaint involving Thomas’s conduct in which the customer requested unspecified damages supported by allegations that the customer’s investment instructions were not followed and that unauthorized trades were executed in the customer’s account while Thomas was associated with European Community Capital. Another customer initiated investment related complaint concerning Thomas’s activities was settled to resolve accusations that Thomas effected unauthorized options trades in the customer’s First Montauk Securities Corp account.
Thomas was discharged by Network I on March 13, 2018 based upon allegations that he did not comply with an internal probe into his activities.
