Imran N. Razvi (also known as Raz Razvi) of Frederick Maryland a stockbroker formerly registered with Lincoln Financial Securities Corporation has been fined $5,000.00 and suspended for six months from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity based upon findings that Razvi engaged in outside business activities which involved the sale of Woodbridge notes without disclosing this to Lincoln Financial. Letter of Acceptance Waiver and Consent No. 2018058057401 (Mar. 5, 2020).
According to the AWC, a company was established by Razvi in April of 2014 to sell insurance products to customers. The company was owned and operated by Razvi and he enlisted multiple agents to work for him. On December 15, 2016, Lincoln Financial was asked by Razvi for permission to engage in outside activities for the company he created.
The AWC stated that through his company, Razvi aimed to refer investors to a purported real-estate investment fund known as Woodbridge Group of Companies LLC. Razvi’s request had been denied by Lincoln on February 7, 2017. The AWC also stated that he was not permitted by the securities broker dealer to receive any compensation or other type of consideration for referring investors to Woodbridge.
Razvi failed to abide by Lincoln Financial’s stance on his Woodbridge referrals since investors were referred to Woodbridge by the agents of Razvi’s company. FINRA stated that commissions were received by the agents as a result of those referrals and that commissions had been paid to Razvi’s company. FINRA determined that Razvi’s undisclosed outside business activities constituted the violation of FINRA Rules 2010 and 3270.
FINRA noted that a Chapter 11 bankruptcy petition was filed by Woodbridge in December of 2017. Securities and Exchange Commission (SEC) charged Woodbridge and its owner Robert Shapiro with running a Ponzi scheme. On December 27, 2018, a judgement was entered against Shapiro which enjoined him from committing future federal securities laws violations and mandated $18,546,643.00 in disgorgement and payment of a $120,710,256.69 fine. Securities and Exchange Commission v. Robert H. Shapiro et al. Case No. 17-24624-MGC.
FINRA Public Disclosure reveals that Razvi has been identified in two customer initiated investment related disputes concerning accusations of his misconduct during the time that he was employed by Lincoln Financial. On July 29, 2019, a customer initiated investment related arbitration claim in reference to Razvi’s conduct was resolved for $32,514.05 in damages based upon accusations of Razvi’s bad recommendations of a non-registered mortgage investment fund for the customer. FINRA Arbitration No. 18-02985. The claim also alleged that the risks of this non-registered investment was not disclosed to the customer.
On July 29, 2019, another customer initiated investment related arbitration claim pertaining to Razvi’s conduct was settled for $67,485.95 in damages supported by allegations that investment recommendations were in no way suitable for the customer and that omissions were made about a non-registered mortgage investment fund purchased by the customer. FINRA Arbitration No. 18-00426. Razvi’s registration with Lincoln Financial was terminated on March 1, 2018.