Securities Arbitration Lawyer Blog
FINRA has suspended former Cambridge Investment Research, Inc. broker Keith Holcomb from the securities industry for 6 months for borrowing money from a customer without notifying or receiving approval from his firm. Holcomb was also fined $7,500.
The conduct is alleged to have taken place while Holcomb was registered with MML Investors Services, LLC in Warwick, Rhode Island.
If you have lost money with Keith Holcomb, MML Investors Services, LLC or Cambridge Investment Research, Inc., contact New York securities arbitration lawyers Iorio Altamirano LLP for a free and confidential evaluation of your account.
FINRA Letter of Acceptance, Waiver, and Consent (“AWC”)
Keith Holcomb and FINRA entered into a Letter of Acceptance, Waiver, and Consent (“AWC”) on March 29, 2021 over the following findings:
- In a March 2019 Form U5 Amendment, MML Investors Services reported a complaint by a customer that beginning in 2016, Holcomb borrowed money from her without a repayment schedule and had not repaid her.
- MML Investors Services’ written supervisory procedures prohibited borrowing money from customers unless the customer qualified as “immediate family” under Rule 3240(c) and the representative provided the firm advance notice and received advance written approval.
- Holcomb became the customer’s broker in early 2016, after her previous broker left the firm. By the end of 2016, Holcomb understood that the customer was not financially secure and suffered from serious health problems.
- Between November 2016 and June 2017, when Holcomb left MML Investors Services, Holcomb borrowed at least $31,420 from the customer. As of the date of the AWC, he has only repaid $1,007. The customer was not a member of Holcomb’s immediate family, and Holcomb never notified or sought preapproval from MML Investors Services before borrowing from her as required.
- Holcomb violated FINRA Rules 3240 and 2010 by borrowing at least $31,420 from a customer without notifying or receiving approval from his member firm.
FINRA Rules 3240 and 2010
FINRA Rule 3240(a) states that a registered representative may not borrow money from any customer unless his member firm has written procedures that allow for such borrowing and the borrowing arrangement meets certain other conditions.
FINRA Rule 3240(b) generally requires a registered representative to notify his member firm and obtain written pre-approval of his borrowing arrangement with a customer.
A violation of Rule 3240 is also a violation of FINRA Rule 2010, which requires member firms and their associated persons to observe high standards of commercial honor and just and equitable principles of trade.
Keith Holcomb (CRD#: 6227200)
Holcomb has 3 years of experience in the securities industry and has been registered as a broker with the following firms:
- Cambridge Investment Research, Inc., Pawtucket, RI (September 26, 2017 – May 6, 2019);
- MML Investors Services, LLC, Warwick, RI (September 18, 2015 – June 22, 2017); and
- NYLIFE Securities LLC, Providence, RI (March 16, 2015 – September 3, 2015).
Holcomb is not currently registered or associated with a FINRA member but remains subject to FINRA’s jurisdiction.
How to Recover Losses or Obtain a Free Consultation
If you have lost money with Keith Holcomb, MML Investors Services, LLC or Cambridge Investment Research, Inc., contact New York securities arbitration lawyer Jorge Altamirano of Iorio Altamirano LLP at jorge@ia-law.com or toll-free at (855) 430-4010 for a free and confidential evaluation of your account.
Iorio Altamirano LLP is a securities arbitration law firm based in New York, NY. We pursue FINRA arbitration claims nationwide on behalf of investors to recover financial losses arising out of wrongful conduct by financial advisors and brokerage firms.