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Regulation and Compliance > Federal Regulation > FINRA

Ex-JPMorgan Rep Barred for Refusing to Cooperate in FINRA Probe

By Jeff Berman

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The Financial Industry Regulatory Authority last week provided another reminder to brokers that ignoring its information requests or lying to it during an investigation can lead to them being booted from the industry as it barred ex-reps of JPMorgan Securities and TGP Securities.

First, without admitting or denying FINRA’s findings that included a claim she didn’t cooperate with an investigation, former JPMorgan rep Forouzan Pooladi submitted a letter of acceptance, waiver and consent to FINRA July 30 in which she agreed to FINRA’s sanction. FINRA accepted the letter Wednesday.

JPMorgan and Pooladi didn’t immediately respond to requests for comment Monday.

Pooladi was registered with FINRA through JPMorgan as an investment company shares and variable contracts representative starting in May 2016, according to FINRA.

The firm filed a Form U5 on Oct. 4, 2019, saying she was “terminated for violating affiliate bank policy governing personal finances by conducting numerous transactions under the currency transaction reporting threshold; and for performing an affiliate bank transaction between a business customer and husband’s personal affiliate bank account,” according to the AWC letter.

In July 2020, Pooladi “refused to respond to an information request” by FINRA, violating FINRA Rules 8210 and 2010, according to FINRA.

Second FINRA Action

Without admitting or denying FINRA’s findings that included a claim he provided false written statements and testimony, former broker Andrew M. Arthur submitted a letter of acceptance, waiver and consent to FINRA Aug. 9 in which he agreed to FINRA’s sanction. FINRA accepted the letter Thursday.

From August 2014 to July 2017, Arthur was associated with Guggenheim Securities as a general securities representative and general securities principal, according to FINRA. From September 2017 to September 2018, Arthur was registered as a GSR and GP through an association with FINRA member GMP Securities (now owned by Stifel). In May 2019, Arthur registered as a GSR and GP through an association with FINRA member TGP Securities.

In a Form U5 dated August 13, 2019, TGP reported the voluntary termination of Arthur, the AWC letter said, without giving a reason. Arthur previously signed AWC letters in 2015 and 2018, agreeing to be suspended and fined $5,000 on each occasion for failing to amend his Form U4 to report a tax lien and submitting falsified brokerage account statements to third parties, respectively, according to FINRA.

From October 2016 through September 2019, Arthur converted $275,000 given to him by a relative, according to the AWC letter. Arthur obtained the funds by falsely representing that the $275,000 would be invested in private placements via an employee investment program offered by Arthur’s then-member-firm employer, according to FINRA.

“In fact, the ‘investment program’ was fictitious and Arthur converted the $275,000 to pay personal expenses and to repay other individuals from whom Arthur had previously received money,” FINRA alleged.

Arthur then “falsely represented in a written statement and falsely testified during his April 2018 on-the-record interview (OTR) that he did not forward a fictitious Firm e-mail he created to any third-party,” FINRA claimed.  “Arthur also falsely represented in a written statement that the funds he received from the relative were a personal loan,” according to the AWC letter.

By providing false and misleading information to FINRA, Arthur violated FINRA Rules 8210 and 2010, according to FINRA.

James Tammaro, TGP CEO and president, declined to comment Friday. Guggenheim, GMP and Daniel Nathan, an attorney at law firm Orrick Herrington & Sutcliffe who represented Arthur in the dispute, did not immediately respond to requests for comment.

Jeff Berman

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