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William Walter LeBoeuf (also known as Bill LeBoeuf), of Beavercreek, Ohio, a stockbroker formerly registered with Cetera Advisor Networks LLC and Merrill Lynch Pierce Fenner Smith Inc., has been fined $12,500.00 and suspended for twelve months from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity based upon findings that he engaged in outside business activities and private securities transactions, and sent prospective customers investment presentations that omitted risks about investing. Letter of Acceptance, Waiver, and Consent No. 2019064823601 (November 23, 2021).

According to the AWC, in December of 2017, while LeBoeuf was registered with Merrill Lynch Pierce Fenner Smith, he solicited a customer for an investment in Fund A. FINRA indicates that Fund A was a pooled real estate investment fund. LeBoeuf engaged in activities on behalf of the client relating to this investment, including meeting with Fund A’s promoter and advising LeBoeuf on how much to invest. LeBoeuf then facilitated the customer’s $250,000.00 investment in Fund A.

FINRA states that in 2019, when LeBoeuf was employed by Cetera Advisor Networks, he approached customers for investments in Company B’s convertible promissory notes. Emails were sent to customers by LeBoeuf regarding the investment. The emails contained LeBoeuf’s recommendations of the purchase amount. Subsequently, a limited liability company was created by LeBoeuf to facilitate purchases of investments in Company B. Three customers of Cetera Advisor Networks collectively invested $750,000.00 in the convertible promissory notes.

According to the AWC, there was no point where LeBoeuf asked for permission from Cetera Advisor Networks or Merrill Lynch to engage in these transactions. He was never provided with written approval from the securities broker dealers. The stockbroker was also issued annual compliance questionnaires while at Merrill Lynch that he falsely responded to. FINRA determined that LeBoeuf violated FINRA Rules 2010 and 3280 by engaging in undisclosed private securities transactions.

The AWC states that LeBoeuf also engaged in undisclosed outside business activities. On July 17, 2019, articles of incorporation were filed by LeBoeuf to establish Accelerate Capital Partners LLC (ACP). LeBoeuf was listed as ACP’s member and manager. FINRA states that ACP was designed to facilitate the investments made by customers in Company B. It was not until August 1, 2019, that LeBoeuf told Cetera Advisor Networks about this. He violated FINRA Rules 2010 and 3270 for this reason.

LeBoeuf also made misleading communications to prospective investors. FINRA states that when investors were solicited by LeBoeuf regarding Company B, they received a presentation regarding the investment opportunity. Twelve investors, including Cetera Advisor Networks customers, received investment information that did not fully disclose the risks of investments, including illiquidity and the possibility of investment loss. LeBoeuf violated FINRA Rules 2010 and 2210(d)(1)(A).

LeBoeuf was registered with Merrill Lynch between September 2, 2009, and March 29, 2019, and registered with Cetera Advisor Networks between March 28, 2019, and December 5, 2019.