Insufficient funds in advisor’s bank account to cover transfer: An individual was fined $5,000 and suspended for two years for making payments totaling approximately $180,000 from funds credited to his brokerage account as a result of multiple transfers sent from his personal bank account, when he knew that his bank account lacked funds to cover the transfers. The findings stated the individual paid ongoing expenses from the transfer amounts initially credited to the brokerage account before his firm reversed the transfers due to insufficient funds in his bank account. This caused a negative balance in the brokerage account, approximately $52,000 of which he has failed to repay.
Advisor’s trustee role included investment decisions: An individual was fined $5,000 and suspended for six months for making inaccurate statements to her member firm when seeking approval to serve as the trustee of a private foundation funded with assets from a customer’s estate. The findings stated the individual certified to the firm that they would not have direct or indirect control over the investment decisions for the foundation. However, the advisor opened a brokerage account at a different firm for the foundation, where they had control over and made investment decisions on the foundation’s behalf.
Advisor had an LLC without Firm approval: An individual was fined $5,000 and suspended for two months for engaging in an OBA without prior disclosure to his firm and then contrary to the directive of the firm. The individual was a member and a fifty percent owner of an insurance agency that was organized as a limited liability company (LLC). The individual failed to disclose this to his firm and ultimately the firm denied him permission to participate. Nevertheless, Ramirez continued the activity until his resignation from the firm.
Use of personal email for business: An individual was barred for use of personal email for his firm’s business and sharing of confidential customer information with unauthorized third parties. The individual’s initial response to FINRA was incomplete and he refused to provide the additional information requested.
Please contact the Prosperity Network Compliance Team with any questions: compliance@prosperityadvisors.com or 913-529-5500 Option 2.
Internal Use Only
Attachment: November 2025 FINRA Real-World Disciplinary Action