Robert Edward White (White) submitted a Letter of Acceptance, Waiver and Consent (“AWC”) pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure to settle allegations he accepted a substantial amount of monetary gifts from a customer without proper disclosure to his firm. As a result, the Financial Industry Regulatory Authority (FINRA) suspended White for four (4) months.
White (FINRA CRD No. 3077959) entered the financial industry in 1998 as a general securities representative. From 2002 to 2017, and during the relevant time period, White worked for Raymond James Financial Services, Inc. (“Raymond James”). Raymond James fired White in April 2017 for the reasons discussed here. White is no longer associated with any FINRA member; however, he remains subject to FINRA’s disciplinary powers.
FINRA’s Department of Enforcement investigated White and alleged he accepted approximately $58,000 in gifts from a firm customer. Raymond James had a policy prohibiting registered representatives from accepting monetary payments and/or gifts in excess of $100 per year from firm customers. Nevertheless, White lied and certified to Raymond James that he had not received excessive gifts from any customer.
Based upon the foregoing misconduct, FINRA alleged White violated FINRA Rule 2010. For example, “[i]t is well established that conversion violates the ‘high standards of commercial honor and just and equitable principles of trade’ required by FINRA Rule 2010.’” Here, White’s misconduct involving the receipt of undisclosed gifts was not just and equitable.
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