Sanjay Bhargava of Independence, Ohio, a stockbroker formerly registered with Securities America Inc., has been fined $5,000.00 and suspended for three months from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity based upon findings that Bhargava took part in private securities transactions during the time that he was employed by Securities America. Letter of Acceptance, Waiver, and Consent No. 2020066655701 (May 13, 2022).

According to the AWC, while associated with Securities America, Bhargava referred customers to Broker 1 for accounting and tax work. By November of 2018, a limited liability company was created by Broker 1 to pool investment funds in private placement offerings. The AWC states that the offerings were issued by Company A, which preserved and operated special types of real estate, including historic properties. The AWC states that Company A’s offering concerned a Salt Lake City, UT hotel. Investors were told about receiving possible tax credits relating to their investments if qualified.

The AWC shows that Bhargava helped forge the relationship between Broker 1 and Company A. FINRA states that in November of 2018, Company A was in communications with Bhargava about the offering, including how investors with Broker 1 would invest in the offering of Company A. Bhargava also personally spoke with some investors about the offering.

FINRA states that on November 23, 2018, six investors (none with Securities America accounts) had agreed to invest $341,250.00 in the LLC in part because of Bhargava’s help.

On December 9, 2018, Securities America had Bhargava complete an annual compliance questionnaire which included questions about Bhargava’s potential selling away activities. Bhargava stated that he did not have any involvement in private securities transactions. FINRA states that Bhargava misrepresented his response to this questionnaire, and he engaged in private securities transactions in violation of FINRA Rules 2010 and 3280.

FINRA Public Disclosure shows that Bhargava is referenced in a customer initiated investment related FINRA securities arbitration claim where the customer was awarded $32,606.94 in compensatory damages based on Bhargava being found liable on the customer’s claims of sales practice violations. The Statement of Claim alleges omissions, misrepresentations, violation of NYSE and FINRA rules, unsuitable trading, breach of contract, breach of fiduciary duty, and fraud relating to the customer’s investment in Behringer Harvard REIT 1. Bhargava made an unsuitable recommendation to the customer, given the customer’s needs and risk tolerance.

Bhargava was registered with Securities America between February 16, 2011, and May 13, 2020. He was permitted to resign founded on accusations of his unauthorized activities. Bhargava was also registered with Arbor Point Advisors between January 20, 2016, and May 13, 2020. He has been registered with Regulus Financial Group LLC as a stockbroker since May 21, 2020, and Regal Investment Advisors LLC as an investment adviser representative since July 19, 2020.