According to FINRA’s Disciplinary and Other FINRA Actions publication, Thomas Edward Brenner Jr. (CRD #1489233) of Orrville, Ohio submitted to an Acceptance, Waiver & Consent (“AWC”) with FINRA in which he was assessed a fine of $30,000, suspended from association with any FINRA member in any capacity for 16 months, and ordered to pay deferred disgorgement of commissions of $189,000, plus interest.
FINRA alleged that Thomas Brenner engaged in two separate private placements which were rife with supervisory and substantive violations. FINRA alleged that in soliciting customers to purchase a private placement offering, Brenner provided customers with a private placement memorandum (PPM) for the offering and a program summary, the latter of which provided a brief summary of the offering. FINRA alleged that both the PPM and the program summary contained several statements that claimed or implied that the investments were secured, or suggested a level of safety in the investments or reliability in forecasting returns by investors.
FINRA further alleged that in soliciting investors for another offering, Brenner provided each investor with an application form, a subscription agreement, a promissory note and an executive summary generally describing the offering. FINRA also alleged that at various times while Brenner was soliciting investors in this offering, a founder of the offering told Brenner that a PPM was forthcoming, but, the PPM was not completed until after FINRA’s investigation of the offering began and well after Brenner had ceased soliciting investors, hence, the PPM was not provided to investors. FINRA alleged that by distributing a variety of documents to investors in each offering, Brenner negligently made untrue statements of material facts or omitted to state material facts necessary to make the statements made, in the light of the circumstances under which they were made, not misleading, and made statements which were not fair and balanced, and were misleading, exaggerated and unwarranted.
As a result of the foregoing Thomas Brenner was fined and suspended by FINRA. The suspension is in effect from August 15, 2016, through December 14, 2017. (FINRA Case #2015046056403)
According to FINRA’s Broker Check, Thomas Brenner was registered with the securities industry for thirty (30) years, and was registered with the following firm(s):
First American Securities, Inc.
11/2011 – 06/2016
Capstone Financial Group, Inc.
Forest Lake, MN
08/2010 – 11/2011
First Allied Securities
07/2007 – 08/2010
Raymond James Financial Services, Inc.
06/1991 – 07/2007
Edward Jones & Co. L.P.
St. Louis, MO
04/1986 – 06/1991
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