Our firm is investigating NYLIFE Securities LLC broker and Eagle Strategies LLC investment adviser representative Jason S. Min (CRD# 3220191) of La Cañada Flintridge, California for potential investment-related misconduct.
Financial Advisor’s Career History
Jason S. Min (CRD# 3220191) has been in the securities industry since 1999. According to his FINRA BrokerCheck report, he is currently registered with the following firms:
- NYLIFE Securities LLC (CRD# 5167), based in New York, New York, where he has been registered as a broker since December 8, 1999. His branch office location is in La Cañada Flintridge, California.
- Eagle Strategies LLC (CRD# 110826), an investment adviser firm based in New York, New York, where he has been registered as an investment adviser representative since February 28, 2005, also operating out of La Cañada Flintridge, California.
His BrokerCheck report further shows that he was previously registered with:
- WMA Securities, Inc. (CRD# 32625) in Duluth, Georgia, from October 1999 to November 1999.
In addition, Min has reported employment as an agent of New York Life Insurance Company in Los Angeles, California, beginning in November 1999, during which he has also brokered various non-registered insurance products.
Jason S. Min Fraud Allegations and Investor Complaints Explained
Public records on FINRA BrokerCheck disclose one pending customer dispute involving Jason S. Min related to variable annuity business at NYLIFE Securities LLC.
According to the report:
- Employing firm at the time of the alleged conduct: NYLIFE Securities LLC
- Nature of product: Variable annuities
- Dates of the underlying transactions: Policies purchased in May 2025 and June 2025
- Date the complaint was received: October 23, 2025
- Status: Complaint is pending
- Allegations:
- The customer alleges that he was misled regarding the variable annuity surrender charges associated with the policies he purchased in May 2025 and June 2025.
- Alleged damages:
- The complaint lists alleged damages as “$0.00,” but NYLIFE Securities states that, although the customer has not specified a dollar amount, the firm has made a good-faith determination that the alleged damages would exceed $5,000.00.
At this stage, the customer dispute is pending, and there has been no reported settlement, adjudication, or award. No individual contribution or settlement amounts are listed for Min, and there is no indication of any final finding of liability against him in the disclosure.
Summary of Reported Disclosure
- Type of disclosure: Customer dispute (written complaint)
- Status: Pending
- Reporting source: Broker
- Firm involved: NYLIFE Securities LLC
- Product involved: Variable annuities
- Alleged misconduct: Misleading the customer about variable annuity surrender charges on multiple policy purchases in 2025
- Alleged damages: Not specified by the customer; the firm estimates that alleged damages would exceed $5,000
- Regulatory outcome: None yet; the matter remains unresolved and contested
Investors should understand that a pending complaint is an allegation only. It has not been proven and may ultimately be dismissed, resolved in the broker’s favor, or settled without any admission of wrongdoing. However, allegations involving misleading disclosures about surrender charges in variable annuities are serious because they go to the heart of the broker’s duties regarding suitability, disclosure of costs, and fair dealing with customers.
Additional FINRA Disclosures
Aside from this pending customer dispute, Min’s BrokerCheck report does not disclose other customer complaints, regulatory actions, criminal matters, or terminations for cause. The single reported disclosure event is:
- Customer Dispute: 1 (pending)
- Regulatory, criminal, financial, or other disclosures: None reported in BrokerCheck at this time
Investors who purchased variable annuities through Jason S. Min, particularly around May and June 2025, and who were not fully informed about surrender charges, lock-up periods, or other material costs, may wish to have their accounts and transaction histories reviewed by an experienced securities attorney.
To obtain a copy of Jason S. Min’s FINRA BrokerCheck report, visit this link.
Robert Wayne Pearce Is Committed to Recovering Your Investment Losses
FINRA Rule 2111 (Suitability) in the Context of the Alleged Misconduct
FINRA Rule 2111 (Suitability) requires that a broker have a reasonable basis to believe that a recommended transaction or investment strategy is suitable for the customer, based on the customer’s investment profile, including age, financial status, tax status, investment objectives, risk tolerance, time horizon, and liquidity needs.
In the context of the complaint against Jason S. Min, the customer alleges he was misled about variable annuity surrender charges on policies purchased in May and June 2025. If a broker recommends a variable annuity, suitability under Rule 2111 generally includes:
- Understanding and explaining surrender periods and surrender charges;
- Considering whether the customer might need access to their funds during the surrender period;
- Evaluating whether the costs, riders, and features of the annuity are justified given the client’s objectives and risk tolerance;
- Avoiding recommendations that tie up funds in long-term products when the customer has short-term liquidity needs.
If it were proven that Min recommended variable annuities without adequately disclosing surrender charges or without reasonably considering the client’s time horizon and liquidity needs, regulators or arbitrators could conclude that such recommendations failed to satisfy Rule 2111’s suitability and reasonable-basis obligations. Conversely, if full disclosure was provided and the products were appropriate for the client’s profile, those facts could support a finding that Rule 2111 was not violated.
FINRA Rule 2330 (Members’ Responsibilities Regarding Deferred Variable Annuities)
FINRA Rule 2330 specifically addresses members’ and associated persons’ responsibilities regarding recommended purchases and exchanges of deferred variable annuities. Among other things, Rule 2330 requires that:
- Firms and brokers have a reasonable basis to believe the customer has been informed, in general terms, of the material features of the annuity, including:
- Surrender periods and surrender charges
- Potential tax penalties
- Mortality and expense fees
- Market risk and other costs
- Brokers consider and document the customer’s age, liquidity needs, financial situation, investment experience, and other relevant factors;
- Firms implement procedures for review and approval of variable annuity purchases and exchanges.
Where a customer alleges he was misled about surrender charges associated with variable annuity policies, as in the pending complaint involving Jason S. Min, Rule 2330 is often a focal point because it expressly calls out the need to inform customers about surrender periods and charges.
If a fact-finder ultimately determines that Min or his firm failed to reasonably inform the customer of surrender charges or did not adequately evaluate the customer’s ability to bear those charges, they could find a violation of Rule 2330. If, on the other hand, the evidence shows that surrender charges were fully disclosed, properly documented, and consistent with the customer’s needs and investment profile, Rule 2330 might be deemed satisfied.
FINRA Rule 2010 (Standards of Commercial Honor and Principles of Trade)
FINRA Rule 2010 requires members and associated persons to “observe high standards of commercial honor and just and equitable principles of trade.” This broad rule often serves as a catch-all when a broker’s conduct—such as misleading statements, half-truths, or omissions about costs and restrictions—falls short of basic fairness, even if no more specific rule is directly implicated.
In cases involving alleged misrepresentation of surrender charges, regulators and arbitration panels may consider whether:
- The broker’s explanations of fees and surrender schedules were clear, accurate, and complete;
- Any statements downplayed or obscured the true cost of exiting the variable annuity early;
- The broker’s sales practices were driven by commissions at the expense of the client’s interests;
- The overall pattern of communication and documentation aligns with the “high standards of commercial honor” required by Rule 2010.
If the allegations against Jason S. Min were ultimately proven—that the customer was materially misled about surrender charges—those facts could support a finding that his conduct violated Rule 2010. If the evidence instead shows accurate and complete disclosure, good-faith communication, and adherence to firm procedures, then a Rule 2010 violation may not be found.
For over 45 years, Robert Wayne Pearce has helped investors recover losses caused by broker fraud, negligence, and unsuitable recommendations. His firm, The Law Offices of Robert Wayne Pearce, P.A., represents clients nationwide on a no-recovery, no-fee basis. Call (800) 732-2889 or email pearce@rwpearce.com for a free case review with an experienced securities attorney.