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FINRA Sends Ex-LPL Rep Back to School

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The Financial Industry Regulatory Authority is sanctioning an ex-LPL Financial rep who violated private securities transaction rules by requiring him to attend and satisfactorily complete 20 hours of continuing education concerning registered representatives’ regulatory responsibilities, according to FINRA.

Without admitting or denying the findings, Sean P. Waggoner signed a FINRA letter of acceptance, waiver and consent Dec. 19 in which he agreed to get those extra hours of education from a “provider not unacceptable to FINRA.”

Waggoner also accepted two other sanctions that FINRA imposed on him: a $10,000 fine and a suspension from association with any FINRA member firm for two months. FINRA accepted the letter Tuesday.

LPL did not provide a comment by our deadline. Todd Murray, a lawyer at Foley & Lardner in Dallas, Texas, who represented Waggoner in the case, didn’t immediately respond to a request for comment.

Between March 2010 and May 2016, Waggoner “participated in eight private securities transactions without providing prior written notice to his firm,” violating NASD Rule 3040 and F1NRA Rules 3280 and 2010, according to the FINRA letter. Those purchases were “made on his own behalf” and fell “outside the scope” of his employment with LPL, FINRA said.

In addition, between June 2014 and January 2017, Waggoner failed to provide prior written notice to his firm about eight personal brokerage accounts held at another FINRA member firm, violating NASD Rule 3050(c) and FINRA Rule 2010, FINRA said.

“In or around June 2014, while Waggoner was associated with LPL, his broker for those eight accounts moved to a different member firm and Waggoner opened eight brokerage accounts at that firm,” according to the FINRA letter. Waggoner indicated on the account opening documents that he was not affiliated with or employed by a FINRA member firm, FINRA noted, adding the rep also “did not disclose the accounts to LPL.” In fact, “to the contrary, Waggoner signed and submitted annual compliance questionnaires to LPL in which he inaccurately represented that he did not have any undisclosed outside securities accounts,” FINRA said.

There are no disclosures listed on Waggoner’s profile on FINRA’s BrokerCheck website. It shows that he has worked for five FINRA member firms over the course of 23 years.

— Check out FINRA Bars Ex-Merrill Rep Who Refused to Testify on ThinkAdvisor.


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