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Finra bars two ex-Raymond James advisors who sold unapproved products

Firms must take reasonable steps to avoid financial advisors' selling away, one compliance expert noted.

Two Raymond James Financial Services Inc. financial advisors on Monday were barred from the securities industry for not cooperating in investigations, according to the Financial Industry Regulatory Authority Inc.; both had previously been flagged by Raymond James for selling products to customers the firm had not signed off on as well as selling away, which involves offering clients investments that are not approved by the firm.

Bryan Noonan sold an “unapproved investment,” while Thomas Reyes sold annuities not sanctioned by the firm. Both failed to cooperate with Finra’s investigation, a flouting and violation of rules that leads to the self-regulator barring the financial advisor from working in the securities industry.

Raymond James Financial Services is the independent contractor broker-dealer arm of Raymond James Financial Inc., which has more than 8,700 financial advisors across its various work platforms.

“When it comes to products that have not been ok’d or outside business activities by advisors, firms can’t be reactionary or do the work after the fact,” said Sander Ressler, managing director of Essential Edge Compliance Outsourcing Services. “They must take reasonable steps to prevent and detect this kind of behavior under Finra’s supervision rules, and use all tools available, including government databases, to do so.”

Both Noonan and Reyes agreed to the Finra settlement without admitting to or denying Finra’s findings in their respective matters. Noonan did not respond to a message left at his office and Reyes’ attorney did not return a phone call. A spokesperson for Raymond James declined to comment.

Noonan worked in Scottsdale, Ariz., for Raymond James Financial Services from July 2021 through this March, according to his BrokerCheck profile. In his notice of termination filed with Finra, the firm noted there was internal review pending “relating to possible violations of the firm’s policies relating to
outside business activities and selling away,” according to the Finra order.

The firm this month filed an amended report stating that the internal review determined that Noonan, and his clients, invested in an unapproved investment, according to Finra.

Reyes worked in La Vista, Neb. for the firm from June 2015 to March 2022, according to his BrokerCheck report. In his notice of termination, Raymond James reported an internal review “concerning potential undisclosed outside business activity” by Reyes, according to Finra.

In August 2022, Raymond James made another filing with Finra disclosing that its internal review in the matter concluded that Reyes “sold annuities that were not on the firm’s approved product list away from the firm.”

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