Tonya Nicole Smoake of Franklin Lakes New Jersey a stockbroker formerly registered with Purshe Kaplan Sterling Investments has been fined $5,000.00 and suspended for one year from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity supported by findings that she engaged in private securities transactions during the period that she was associated with Purshe Kaplan Sterling Investments. Letter of Acceptance Waiver and Consent No. 2019062886902 (Mar. 16, 2021).
According to the AWC, between April of 2017 and September of 2017, at least $850,000.00 worth of investor transactions had been facilitated by Smoake away from Purshe Kaplan Sterling Investments. Four investors collectively contributed funds towards a registered investment advisory through a private placement offering. The AWC stated that between September of 2018 and January of 2019, at least $780,000.00 in additional investment transactions had been facilitated by Smoake. These transactions involved eight investors who contributed funds towards the holding company of the registered investment advisory through a private placement offering.
FINRA indicated that when these Regulation D transactions took place, Smoake was the registered investment advisory’s Chief Executive Officer. Her involvement in the transactions involved providing investors with offering documents and procuring all completed documents from them relating to their purchases. She also provided investors with important information about the private placements and had made arrangements for investors to make their purchases.
FINRA indicated that Purshe Kaplan Sterling Investments was not provided with written notice concerning Smoake’s involvement in the securities transactions. The regulator also pointed out that between November of 2017 and November of 2018, Smoake was provided with annual compliance questionnaires that she falsely completed. The stockbroker relayed to Purshe Kaplan Sterling Investments that she was not involved in any selling away activities. FINRA determined that Smoake’s conduct was violative of FINRA Rules 2010 and 3280.
FINRA Public Disclosure also confirms that on March 2, 2020, Smoake became the subject of a FINRA investigation concerning potential private securities transactions relating to an Avestar Capital LLC Chief Executive Officer.
Smoake was registered with Purshe Kaplan Sterling Investments between March 23, 2017 and May 14, 2019. Between May 16, 2019 and September 9, 2020, she was registered with Bhargava Capital.
