Tuesday, June 4, 2013

LPL FINANCIAL CENSURED AND FINED FOR FAULTY SUPERVISORY SYSTEMS GOVERNING DELIVERIES OF MUTUAL FUND PROSPECTUSES

LPL Financial LLC, a Boston, Massachusetts based brokerage firm, submitted a letter of acceptance, waiver, and consent to resolve Financial Industry Regulatory Authority (FINRA) findings that it failed to establish and maintain an adequate supervisory system and written supervisory procedures (WSPs) reasonably designed to ensure timely delivery of mutual fund prospectuses. FINRA's findings stated that the firm was required to provide each of its customers who purchased a mutual fund with a prospectus for that fund no later than three business days after the transaction. The firm executed approximately 16 million mutual fund purchase or exchange transactions, and several million of these transactions required the firm to deliver a mutual fund prospectus to the purchasing customer. Therefore, the firm was required to establish and maintain a supervisory system and WSPs reasonably designed to monitor and ensure the timely delivery of mutual fund prospectuses. FINRA censured and fined the firm a total of $400,000 for all violations committed.
A prospectus is a document that discloses important information about an investment. It typically provides investors with material information about mutual funds, stocks, bonds, and other investments. Such information generally includes a description of the company's business, financial statements, biographies of officers and directors, detailed information about their compensation, any litigation that is taking place, a list of material properties, and any other material information.
In addition, FINRA's findings stated that the firm relied on its brokers for the delivery of mutual fund prospectuses. Each broker was required to obtain the customer's signature on a prospectus receipt form to have a record of the delivery. However, the firm did not have a supervisory system in place that was reasonably designed to ensure that prospectus receipts had been obtained in connection with mutual fund purchases or that a prospectus had actually been delivered timely. The firm's WSPs did not require an adequate review of its brokers' performance of their prospectus delivery obligations. Instead, the firm's procedures consisted of inadequate measures. FINRA further stated that for some time, the firm was aware that its procedures were failing to ensure that brokers consistently obtained prospectus receipts or other evidence of mutual fund prospectus delivery. On at least two occasions, the firm contemplated proposals to adjust its procedures for tracking prospectus delivery compliance, but the firm did not modify or enhance its procedures and continued to rely upon brokers without adequate safeguards to ensure and monitor mutual fund prospectus delivery.
Have you suffered losses in your LPL Financial brokerage account? If so, call Robert Pearce at the Law Offices of Robert Wayne Pearce, P.A. for a free consultation. Mr. Pearce is accepting clients with valid claims against LPL Financial stockbrokers who may have engaged in misconduct and caused investors losses.
The most important of investors' rights is the right to be informed! This Investors' Rights blog post is by the Law Offices of Robert Wayne Pearce, P.A., located in Boca Raton, Florida. For over 30 years, Attorney Pearce has tried, arbitrated, and mediated hundreds of disputes involving complex securities, commodities and investment law issues. The lawyers at our law firm are devoted to protecting investors' rights throughout the United States and internationally! Please visit our website, www.secatty.com, post a comment, call (800) 732-2889, or email Mr. Pearce at pearce@rwpearce.com for answers to any of your questions about this blog post and/or any related matter.

Monday, June 3, 2013

LINCOLN FINANCIAL SECURITIES CORPORATION SANCTIONED DUE TO VARIOUS SECURITIES INDUSTRY LAWS VIOLATIONS

Lincoln Financial Securities Corporation, a Concord, New Hampshire based brokerage firm, has submitted a letter of acceptance, waiver, and consent in which the firm consented to over 16 Financial Industry Regulatory Authority's (FINRA) findings that it enacted a policy requiring its brokers to complete a variable redemption cover sheet (VRCS) for any variable annuity (VA) redemptions they sold, which included a section to document an economic analysis outlining the redemptions were beneficial to the customers and disclosing if the sale proceeds were intended to purchase a non-securities product. For over a year, the firm failed to ensure that brokers were completing the VRCS form when required to do so. Most of the forms were not completed, so the firm failed to review and supervise the VA redemptions that resulted in subsequent purchases of equity-indexed annuities (EIAs) and fixed annuities. FINRA's findings stated that the firm failed to enforce its supervisory system designed to ensure that recommendations to liquidate or surrender VAs to fund purchases of EIAs or fixed annuities were suitable, and thus failed to supervise these transactions. The firm was censured and fined a total of $525,000 for all violations committed.
FINRA also stated that the firm's written supervisory procedures (WSPs) prohibited its brokers from receiving commissions for securities transactions in customer accounts where the broker was not licensed in both the state of solicitation and the state in which the customer resided. The firm failed to detect around 2,500 transactions in customer accounts despite the fact that the brokers listed on the accounts were not licensed in the state in which the customer resided at the time of the commission payment. Nearly all of these transactions involved previously scheduled, recurring investments in established customer accounts. The findings included that the firm failed to enforce its policies and procedures designed to ensure that all of its brokers were properly licensed in the states where they conducted securities transactions for customers.
In addition, FINRA found that the firm failed to shape the transactional-monitoring aspect of its anti-money laundering (AML) procedures to its business. The firm failed to ensure adequate procedures were in place to watch for suspicious transactions that occurred in client accounts held directly with product manufacturers following the initial investment. The firm knew that subsequent transactions occurring in accounts held directly with product manufacturers were not undergoing AML monitoring by the firm because it was relying on the product manufacturers to review these transactions but did not confirm they were actually performing this review. FINRA also found that the firm's AML training program was inadequate in that it failed to adequately specify the time period for training employees and which employees required training. FINRA further determined that the firm required its brokers when communicating with customers to use a firm account or an outside email address linked to the firm account so all emails could be viewed and retained. However, the firm did not stop its brokers from using outside email addresses for non-securities related matters. Brokers who received securities-related emails through their outside email addresses were required to forward those emails to the firm's account. When an auditor reported that securities-related emails had not been forwarded, the firm failed to employ a system for confirming that its brokers were forwarding all securities-related emails for retention. The firm also failed to have an adequate system in place to confirm whether external email addresses were being used for securities-related correspondence and whether they were retained. FINRA concluded that the firm failed to reasonably enforce its supervisory procedures to ensure that all securities-related emails brokers sent or received were captured, reviewed, and stored.
Moreover, FINRA found that for over a year, the firm failed to reasonably supervise customer account activity and customer files for producing managers. The firm's WSPs permitted its OSJ managers to conduct reviews of their own securities transactions completed on behalf of customers. Firm branch office inspection reports did not ensure that a sufficient sample of the customer files reviewed during branch audits were accounts OSJ managers serviced.
Have you suffered losses in your Lincoln Financial Securities Corporation brokerage account? If so, call Robert Pearce at the Law Offices of Robert Wayne Pearce, P.A. for a free consultation. Mr. Pearce is accepting clients with valid claims against Lincoln Financial Securities Corporation stockbrokers who may have engaged in misconduct and caused investors losses.
The most important of investors' rights is the right to be informed! This Investors' Rights blog post is by the Law Offices of Robert Wayne Pearce, P.A., located in Boca Raton, Florida. For over 30 years, Attorney Pearce has tried, arbitrated, and mediated hundreds of disputes involving complex securities, commodities and investment law issues. The lawyers at our law firm are devoted to protecting investors' rights throughout the United States and internationally! Please visit our website, www.secatty.com, post a comment, call (800) 732-2889, or email Mr. Pearce at pearce@rwpearce.com for answers to any of your questions about this blog post and/or any related matter.

Sunday, June 2, 2013

IMS SECURITIES CENSURED AND FINED DUE TO VARIOUS SECURITIES INDUSTRY VIOLATIONS

IMS Securities, a Houston, Texas based brokerage firm, has consented to Financial Industry Regulatory Authority (FINRA) findings that it registered a number of wholesale representatives, but did not shape its supervisory system to address its new wholesale business in a way that was reasonably designed to achieve compliance with applicable securities laws, regulations and FINRA rules. FINRA's findings stated that although supervising wholesale representatives was different than supervising retail representatives, the firm did not revise its written supervisory procedures (WSPs) or implement any procedures tailored to supervising the wholesale representatives until almost four years after hiring them. Also, FINRA's findings stated that the firm sold a wide range of securities products, including privately-traded real estate investment trusts (REITs) and direct participation plans (DPPs), but the firm did not have sufficient WSPs outlining its procedures for assessing them.
A REIT is a company that owns, and in many cases, operates income-producing real estate. REITs own properties ranging from office and apartment buildings to warehouses, hospitals, shopping centers, and hotels. Some REITs also engage in financing real estate. REITs were designed to provide a real estate investment structure similar to the structure mutual funds provide for investment in stocks.
A DPP is an investment opportunity that allows investors to participate in the profits and tax avoidance of some underlying business. Generally speaking, DPPs invest in real estate or energy products. The concept is to allow investors to participate in certain tax benefits usually available only to corporations, such as depreciation deductions. However, the United States government has curtailed many of the tax benefits available to DPPs. The investment will made up of shares of a partnership, an S corporation, a limited liability company, or any other entity that files an informational return with the IRS but does not itself have any taxable income or deductible losses.
In addition, FINRA's findings mentioned that IMS Securities failed to conduct annual audits at two of its OSJ branch offices one year. FINRA also found that the firm's wholesale representatives used external email addresses to send communications related to its securities business, and the firm failed to store these emails. Moreover, FINRA stated that for nearly two years, the firm failed to adequately maintain purchase/sales blotters and checks received/forwarded blotters, which lacked certain required information. Therefore, the firm failed to maintain blotters reporting a daily record of all purchases and sales of securities, all receipts and disbursements of cash, and all other debits and credits.
Have you suffered losses in your IMS Securities brokerage account? If so, call Robert Pearce at the Law Offices of Robert Wayne Pearce, P.A. for a free consultation. Mr. Pearce is accepting clients with valid claims against IMS Securities stockbrokers who may have engaged in misconduct and caused investors losses.
The most important of investors' rights is the right to be informed! This Investors' Rights blog post is by the Law Offices of Robert Wayne Pearce, P.A., located in Boca Raton, Florida. For over 30 years, Attorney Pearce has tried, arbitrated, and mediated hundreds of disputes involving complex securities, commodities and investment law issues. The lawyers at our law firm are devoted to protecting investors' rights throughout the United States and internationally! Please visit our website, www.secatty.com, post a comment, call (800) 732-2889, or email Mr. Pearce at pearce@rwpearce.com for answers to any of your questions about this blog post and/or any related matter.

Saturday, June 1, 2013

E. S. FINANCIAL SERVICES CENSURED AND FINED FOR MISREPRESENTING COMMERCIAL PAPER PROGRAM

E.S. Financial Services, a brokerage firm based in Miami, Florida, submitted a letter of acceptance, waiver, and consent in which the firm consented to the entry of Financial Industry Regulatory Authority (FINRA) findings that it served as a placement agent and solicited certain non U.S. persons to invest in a commercial paper program offered by an affiliate outside the United States. At various times, in connection with the firm's sales of the commercial paper, the firm provided a customized document to each of the customers or prospective customers, in which the firm included the program in the cash portion of the customer's portfolio alongside U.S. Treasuries and other commercial paper products; labeled the program within investment options described as conservative; and described the main objective of investing in this category as a way to reduce global risk as well as to generate income. The findings stated that the firm recommended investing in the program over U.S. Treasuries or other commercial paper if the customer wanted a higher return. Contrary to the description of the program, it was neither a cash category investment, nor was it a conservative, low-risk investment. The firm was censured and fined $200,000 by FINRA.
Commercial paper is an unsecured, short-term debt instrument issued by a corporation, usually for the financing of accounts receivable, inventories, and meeting short-term liabilities. Maturities are typically less than 270 days, and the debt is usually issued at a discount, reflecting prevailing market interest rates. Commercial paper is not usually backed by any form of collateral, so only firms with high-quality debt ratings will find buyers without having to offer a substantial discount or higher interest rate. Commercial paper does not need to be registered with the Securities and Exchange Commission (SEC) as long as it matures before nine months (270 days), making it a very cost-effective means of financing. The proceeds from this type of financing can only be used on current assets and are not allowed to be used on fixed assets, such as a new plant, without SEC approval.
FINRA stated that E.S. Financial Services' representations amounted to false, exaggerated, or unwarranted statements in the investment program's materials. The findings also stated that the firm posted an information memorandum on a password-protected website accessible to customer that did not adequately detail certain risks associated with investing in the program. In addition, FINRA stated that the firm failed to conduct adequate due diligence relating to its sales of the commercial paper program, and failed to adopt, maintain and enforce adequate written supervisory procedures (WSPs) pertaining to its sale of the investments until almost four years after it began selling the investments. FINRA also included that the firm failed to adopt, maintain and enforce written due diligence procedures tailored to its sale of the investments. Although all of the investments were repaid on a timely basis at maturity, the firm's failure to implement written due diligence procedures led it to fail to conduct a reasonable investigation concerning various matter regarding the investments
Have you suffered losses in your E.S. Financial Services brokerage account? If so, call Robert Pearce at the Law Offices of Robert Wayne Pearce, P.A. for a free consultation. Mr. Pearce is accepting clients with valid claims against Deutsche Bank Securities stockbrokers who may have engaged in misconduct and caused investors losses.
The most important of investors' rights is the right to be informed! This Investors' Rights blog post is by the Law Offices of Robert Wayne Pearce, P.A., located in Boca Raton, Florida. For over 30 years, Attorney Pearce has tried, arbitrated, and mediated hundreds of disputes involving complex securities, commodities and investment law issues. The lawyers at our law firm are devoted to protecting investors' rights throughout the United States and internationally! Please visit our website, www.secatty.com, post a comment, call (800) 732-2889, or email Mr. Pearce at pearce@rwpearce.com for answers to any of your questions about this blog post and/or any related matter.

Friday, May 31, 2013

DEUTSCHE BANK SECURITIES CENSURED AND FINED FOR FAILURE TO DELIVER PROSPECTUSES TO INVESTORS

Deutsche Bank Securities submitted a letter of acceptance, waiver, and consent after the Financial Industry Regulatory Authority (FINRA) entered findings that the firm failed to deliver on time, or failed to ensure that its service provider delivered on time, prospectuses to customers who purchased mutual funds, when in many instances the firm's customers who should have received a prospectus within three business days of the transaction did not. FINRA also found that the firm failed to deliver preliminary IPO prospectuses to certain customers who indicated interest in initial public offerings (IPOs). Deutsche Bank Securities was censured and fined $125,000 after FINRA took into account the fact that the firm self-reported the failures to deliver preliminary IPO prospectuses, self-reported to FINRA that its Global Markets Division did not deliver preliminary IPO prospectuses to certain customers, and took remedial action to correct the non-delivery of the prospectuses.
A prospectus is a document that discloses important information about an investment. It typically provides investors with material information about mutual funds, stocks, bonds, and other investments. Such information generally includes a description of the company's business, financial statements, biographies of officers and directors, detailed information about their compensation, any litigation that is taking place, a list of material properties, and any other material information. In the case of an initial public offering (IPO), a prospectus is required to be delivered by underwriters or brokerage firms to potential investors.
Regarding the mutual fund prospectuses, FINRA's findings stated that Deutsche Bank Securities' clearing firm contracted with a third-party service for the delivery of mutual fund prospectuses for all the clearing firm's introducing brokers, including the Deutsche Bank Securities. On a daily basis, the clearing firm provided the service provider with electronic information pertaining to mutual fund transactions requiring delivery of a prospectus to the firm's customers - they also provided daily and monthly reports to Deutsche Bank Securities. The clearing firm also provided Deutsche Bank Securities with a daily report that identified late prospectus deliveries, including the number of days late and the reason for delay, but the report was never reviewed. FINRA's findings also stated that because of Deutsche Bank Securities' failure to deliver prospectuses on time to a number of customers who purchased mutual funds, these customers were not provided with important information about these products by settlement date. In addition, FIRNA's findings included that the firm failed to implement and maintain a supervisory system and written supervisory procedures (WSPs) reasonably designed to ensure that mutual fund prospectuses were being delivered on a timely basis. Deutsche Bank Securities' WSPs did not require review of the reports provided by its clearing firm that identified late prospectus deliveries and did not require firm personnel to communicate with the service provider. Instead, Deutsche Bank Securities relied upon its clearing firm to ensure the timely delivery of mutual fund prospectuses.
Regarding the IPO prospectuses, FINRA found that Deutsche Bank Securities failed to deliver preliminary IPO prospectuses to customers interested in IPOs. The main cause was the failure of employees within the firm's Global Markets Division to utilize the electronic system designed to ensure delivery of preliminary prospectuses. Because of the Deutsche Bank Securities' failure to deliver preliminary IPO prospectuses to a number of customers interested in purchasing shares in IPOs, these customers were not provided with important disclosures about these products until after they had purchased the shares. FINRA also found that Deutsche Bank Securities was required to establish and maintain a supervisory system and WSPs reasonably designed to monitor and ensure the timely delivery of IPO prospectuses. The Deutsche Bank Securities' systems and procedures were not reasonably designed to ensure that preliminary IPO prospectuses were being delivered to every customer, and therefore failed to implement and maintain such a supervisory system and WSPs.
Have you suffered losses in your Deutsche Bank Securities brokerage account? If so, call Robert Pearce at the Law Offices of Robert Wayne Pearce, P.A. for a free consultation. Mr. Pearce is accepting clients with valid claims against Deutsche Bank Securities stockbrokers who may have engaged in misconduct and caused investors losses.
The most important of investors' rights is the right to be informed! This Investors' Rights blog post is by the Law Offices of Robert Wayne Pearce, P.A., located in Boca Raton, Florida. For over 30 years, Attorney Pearce has tried, arbitrated, and mediated hundreds of disputes involving complex securities, commodities and investment law issues. The lawyers at our law firm are devoted to protecting investors' rights throughout the United States and internationally! Please visit our website, www.secatty.com, post a comment, call (800) 732-2889, or email Mr. Pearce at pearce@rwpearce.com for answers to any of your questions about this blog post and/or any related matter.

Wednesday, May 29, 2013

CAPITOL SECURITIES MANAGEMENT CENSURED AND FINED FOR FAILURE TO DELIVER PROSPECTUSES TO INVESTORS

Capitol Securities Management, a firm based in Glenn Allen, Virginia, consented to the Financial Industry Regulatory Industry's (FINRA) findings that the firm did not have written procedures covering the delivery of exchange-traded fund (ETF) or unit investment trust (UIT) prospectuses. FINRA stated that the firm entered into an agreement with a company for delivery of ETF and UIT prospectuses, but it remained the firm's responsibility to review each transaction and verify that a prospectus was properly delivered when required. Capitol Securities Management submitted a letter of acceptance, waiver, and consent and paid $25,000 to put an end to FINRA's investigation.
A prospectus is a document that discloses important information about an investment. It typically provides investors with material information about mutual funds, stocks, bonds, and other investments. Such information generally includes a description of the company's business, financial statements, biographies of officers and directors, detailed information about their compensation, any litigation that is taking place, a list of material properties, and any other material information. In the case of an initial public offering (IPO), a prospectus is required to be delivered by underwriters or brokerage firms to potential investors.
ETFs are investment funds that are traded on stock exchanges, much like stocks. An ETF holds assets such as stocks, commodities, or bonds, and trades close to its net asset value over the course of the trading day. Most ETFs track an index, such as a stock index or bond index and are attractive investments because of their low costs, tax efficiency, and stock-like features. By owning an ETF, investors benefit from the diversification of an index fund as well as the ability to purchase as little as one share. In addition, expense ratios for most ETFs are lower than those of the average mutual fund. When buying and selling ETFs, investors pay the same commission to their brokers that they would pay on any regular stock order.
UITs are one of three types of investment companies - the other two are mutual funds and closed-end funds - that offer a fixed, unmanaged portfolio, of stocks and bonds, as redeemable "units" to investors for a specific period of time. They are designed to provide capital appreciation and/or dividend income. Each unit typically costs $1,000 and can be resold in the secondary market. A UIT may be either a regulated investment corporation or a grantor trust. The former is a corporation in which the investors are joint owners, and the latter grants investors proportional ownership in the UIT's underlying securities.
In this case, FINRA found that the delivery company made available daily and monthly exception reports through its online report center to help Capitol Securities Management with its delivery obligations. The reports listed all prospectuses not delivered on a trade date and the reason each prospectus was not delivered. However, Capitol Securities Management failed to review the exception reports the company provided and failed to review or monitor the functions it delegated to the company. Therefore the firm failed to deliver the required prospectuses in connection with the ETF and UIT purchases.
Have you suffered losses in your Capitol Securities Management brokerage account? If so, call Robert Pearce at the Law Offices of Robert Wayne Pearce, P.A. for a free consultation. Mr. Pearce is accepting clients with valid claims against Capitol Securities Management stockbrokers who may have engaged in misconduct and caused investors losses.
The most important of investors' rights is the right to be informed! This Investors' Rights blog post is by the Law Offices of Robert Wayne Pearce, P.A., located in Boca Raton, Florida. For over 30 years, Attorney Pearce has tried, arbitrated, and mediated hundreds of disputes involving complex securities, commodities and investment law issues. The lawyers at our law firm are devoted to protecting investors' rights throughout the United States and internationally! Please visit our website, www.secatty.com, post a comment, call (800) 732-2889, or email Mr. Pearce at pearce@rwpearce.com for answers to any of your questions about this blog post and/or any related matter.

Monday, May 27, 2013

FORMER OBSIDIAN FINANCIAL GROUP STOCKBROKER MARK CHRISTOPHER HOTTON NAMED IN FINRA COMPLAINT FOR MISCONDUCT

Former Obsidian Financial Group registered representative Mark Christopher Hotton was named in a Financial Industry Regulatory Industry (FINRA) complaint alleging that while he was employed by Oppenheimer, he improperly used and converted $5,932,000 of customer funds, without his customers knowledge or consent, for his own use and benefit, and caused at least an additional $2,584,078 to be wired from the customers' Oppenheimer accounts to his outside business activities and individual affiliates. Mr. Hotton was allegedly employed by or accepted compensation from outside business entities, which was outside the scope of his relationship with Oppenheimer. Unfortunately, this is not the first set of complaints filed against Mr. Hotton for stock broker misconduct. Numerous customer complaints alleging similar misconduct that go as far back as 1997 were filed against Mr. Hutton while he was employed by American Capital Partners, Oppenheimer, Ladenburg Thalmann, and M.S. Farrell.
In its complaint, FINRA alleges that Mr. Hotton forged and falsified numerous documents and made numerous misrepresentations, verbal and written, to his customers, his firm, and others to further his fraudulent scheme. In addition, the complaint alleges that Hotton provided customers with fabricated statements for a non-existent account at an entity and false written statements about the value of their investments with him. Moreover, the complaint alleges that Hotton exercised control over customers' accounts; recommended and executed transactions that were excessive and unsuitable in light of customers' investment objectives, risk tolerance, and financial situation; loaned $250,000 to firm customers with notifying and receiving written authorization from the firm; he falsely testified during an on-the-record testimony about numerous topics in response to FINRA's questions; he provided FINRA with false statements and claims after authorities made a request for information and documents; and acted with intent to defraud or with reckless disregard for the customers' interests and for the purpose of generating commissions.
Regarding Hotton's U4, FINRA's complaint alleges that he submitted various U4 Forms but failed to disclose his engagement in a number of entities while employed by Oppenheimer; he willfully failed to make any disclosure on his U4 of several legal actions against him, or the settlement of those actions - Hotton failed to disclose that information even after the NASD instructed him to do so; he failed to timely amend his U4 to disclose the commencement of a federal action against him, or the temporary restraining order granted in that action; and when he finally amended his Form U4 to disclose the federal action, he falsely described the action as a business dispute between business partners.
Mr. Hotton also allegedly committed numerous acts of misconduct in clients' accounts and violated his customer-specific suitability obligations. FINRA's complaint states that Hotton executed hundreds of unauthorized trades in customers' accounts without his customers' knowledge, consent, or authorization. FINRA claims that Hotton's customers neither gave Hotton prior written authorization to exercise discretionary powers in their accounts, nor did they give Hotton verbal discretionary power. One of Hotton's customers specifically stated that he was not interested in risky or speculative trading, but Hutton still recommended investments that were contrary to the customer's investment objectives and financial situation. Some of the risky investments recommended were leveraged on inverse exchange traded funds or ETFs, which Hotton did not completely understand. In particular, Hotton did not understand or explain to his clients that the long-term return of a leveraged or inverse ETF can substantially deviate from the underlying index. Therefore, Hotton failed to satisfy the reasonable basis suitability requirement in connection with his investment recommendations.
Have you suffered losses in your Obsidian Financial Group brokerage account? If so, call Robert Pearce at the Law Offices of Robert Wayne Pearce, P.A. for a free consultation. Mr. Pearce is accepting clients with valid claims against Obsidian Financial Group stockbrokers who may have engaged in misconduct and caused investors losses.
The most important of investors' rights is the right to be informed! This Investors' Rights blog post is by the Law Offices of Robert Wayne Pearce, P.A., located in Boca Raton, Florida. For over 30 years, Attorney Pearce has tried, arbitrated, and mediated hundreds of disputes involving complex securities, commodities and investment law issues. The lawyers at our law firm are devoted to protecting investors' rights throughout the United States and internationally! Please visit our website, www.secatty.com, post a comment, call (800) 732-2889, or email Mr. Pearce at pearce@rwpearce.com for answers to any of your questions about this blog post and/or any related matter.