Did you lose money investing with Brad Brooks (CRD# 1584633)?
Galvin Legal, PLLC is launching an investigation on behalf of investors who may have suffered losses investing with Brad Brooks. If you suffered losses investing with Brad Brooks, then Galvin Legal, PLLC may be able to help you recover your losses in a Financial Industry Regulatory Authority (“FINRA“) arbitration claim.
As of October 2, 2020, Brad Brooks’s FINRA BrokerCheck Report contains the following:
6 Customer Dispute(s)
2 Regulatory Event(s)
UPDATE 10/02/2020: According to FINRA’s May 2019 Disciplinary Actions: “JTA Securities Management, Inc. dba Titan Securities (CRD #131392, Addison, Texas), Brad Curtis Brooks (CRD #1584633, Frisco, Texas) and Richard Wayne Demetriou (CRD #828433, Suwanee, Georgia) March 26, 2019 – FINRA appealed an OHO decision to the NAC. On April 1, 2019, Demetriou filed a Notice of Appeal and Cross-Appeal of the OHO decision to the NAC. The firm was fined $50,000 jointly and severally with Brooks and independently fined an additional $15,000. Brooks was suspended from association with any FINRA member in any principal or supervisory capacity for two months. Demetriou was fined $40,000, suspended from association with any FINRA member in all capacities for 21 months and ordered to pay $84,425, plus prejudgment interest, in restitution to customers. The sanctions were based on findings that Demetriou made false or misleading misrepresentations of fact in three widely distributed emails to current and former customers. The findings stated that Demetriou sent investment summaries and emails to his customers and former customers that contained inaccurate information and failed to provide a sound basis for evaluating facts. Demetriou sent the emails without obtaining approval by an appropriately qualified registered principal of the firm. The findings also stated that the firm and Brooks failed to establish, maintain and enforce adequate supervisory systems for the capture, review and retention of the firm’s securities-related emails, failed to enforce the firm’s WSPs prohibiting the use of personal email accounts for securities-related correspondence and that the firm failed to preserve emails relating to its securities business. The findings also included that Demetriou used unauthorized personal email accounts to conduct securities business with customers of the firm. FINRA found that in a minimum-maximum offering of limited partnership units, the firm unlawfully released investment funds from escrow before the minimum offering amount was raised from bona fide investors. FINRA failed to meet its burden of proof that Brooks and the firm made prohibited representations with scienter in connection with the minimum-maximum offering, that Demetriou was employed or compensated as a result of an outside business activity and that the firm and Brooks had an obligation to supervise Demetriou’s involvement in a securities offering as an outside business activity because he was neither employed nor compensated by any person in the offering. Accordingly, these causes of action were dismissed. The sanctions are not in effect pending review. (FINRA Case #2013035345701 Complaint and OHO Decision)
Current and Previous Registrations
10/07/2005 – PRESENT TITAN SECURITIES (CRD#:131392) ADDISON, TX
08/16/2004 – 09/08/2005 SOUTHWEST TEXAS CAPITAL, L.L.C (CRD#:104200) PLANO, TX
05/18/1994 – 06/30/2004 WACHOVIA SECURITIES, LLC (CRD#:19616) ST. LOUIS, MO
07/03/1989 – 05/12/1994 BEAR, STEARNS & CO. INC. (CRD#:79) NEW YORK, NY
11/20/1986 – 07/19/1989 SHEARSON LEHMAN HUTTON INC. (CRD#:7506) NEW YORK, NY
Due Diligence Requirement
FINRA requires broker’s to conduct due diligence on investments and to conduct a suitability analysis when recommending securities to a customer that takes into account the customer’s knowledge and experience. FINRA Rule 2111(a) states that “a member or an associated person must have a reasonable basis to believe that a recommended transaction or investment strategy involving a security or securities is suitable for the customer, based on the information obtained through the reasonable diligence of the member or associated person to ascertain the customer’s investment profile. A customer’s investment profile includes, but is not limited to, the customer’s age, other investments, financial situation and needs, tax status, investment objectives, investment experience, investment time horizon, liquidity needs, risk tolerance, and any other information the customer may disclose to the member or associated person in connection with such recommendation.”
Rule 2111 is composed of three main obligations: reasonable-basis suitability, customer-specific suitability, and quantitative suitability. Brokers and the brokerage firms they work for that fail to conduct adequate due diligence on investments they recommend or that make unsuitable recommendations can be held responsible for the customer’s losses in a FINRA arbitration claim.
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