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Michael DeBoer of Trinity, Florida submitted a Letter of Acceptance, Waiver and Consent (AWC) to the Department of Enforcement of the Financial Industry Regulatory Authority (FINRA) for allegedly not disclosing his participation in a transaction that recommended customers make an unsuitable securities transaction. Mr. DeBoer was registered with former FINRA member firm Dalton Strategic Advisors Investment Services Inc. (Dalton Strategic) from November 2009 to April 2013.

In June 2010, while registered with Dalton Strategic, Mr. DeBoer recommended that two customers invest a total of $200,000 in securities offered by a software development company. Mr. DeBoer received $32,000 in commissions for the securities transaction. However, the investors ultimately lost the entirety of their investments in the securities. FINRA alleged the securities were not offered through Dalton Strategic, and Mr. DeBoer did not disclose his participation in the transactions to his associated firm. FINRA further alleged that before making his recommendation, Mr. DeBoer also failed to reasonably investigate the software company or its securities and therefore lacked a reasonable basis to believe the securities were suitable investments for his clients.

Additionally, FINRA alleged that from November 2010 through December 2012, while registered with Dalton Strategic, Mr. DeBoer “marketed to his customers and other potential investors the services of an entity that provided separately-managed futures trading accounts.” Mr. DeBoer received more than $70,000 in payments from the futures trading entity in return for his referral of approximately 28 people who collectively invested more than $1.8 million. FINRA found that most or all of the people DeBoer referred to the futures trading entity lost a substantial amount of the money they invested.

The alleged conduct would be violations of NASD Rule 3040, NASD Rule 2310, NASD IM-2310-2, and FINRA Rule 2010. Without admitting or denying the FINRA allegations, Mr. DeBoer agreed to the FINRA sanctions and was barred from association with any FINRA member in any capacity.


FINRA rules require brokerage firms to establish and implement a reasonable supervisory system to protect customers from the risks associated with investing. The implementation of the rules requires supervisors to monitor their employees to ensure compliance with federal and state securities laws, securities industry rules and regulations, as well as the brokerage firm’s own policies and procedures. If broker-dealers and their supervisors fail to establish and implement these protective measures, they may be held liable to account holders for investment losses which stem from their employees’ misconduct. Therefore, investors who have suffered losses due to a brokerage firm’s failure to supervise the unsuitable recommendations of its representatives can bring forth claims to recover damages against firms, like Dalton Strategic, which have a duty to supervise employees in order to protect their customers’ interests.

Have you suffered losses in your Dalton Strategic account due to unsuitable investment recommendations? If so, call Robert Pearce at the Law Offices of Robert Wayne Pearce, P.A. for a free consultation. Mr. Pearce is accepting clients with valid claims against Dalton Strategic stockbrokers who may have engaged in misconduct and caused investors losses.

The most important of investors’ rights is the right to be informed!  This Investors’ Rights blog post is by the Law Offices of Robert Wayne Pearce, P.A., located in Boca Raton, Florida.  For over 40 years, Attorney Pearce has tried, arbitrated, and mediated hundreds of disputes involving complex securities, commodities and investment law issues.  The lawyers at our law firm are devoted to protecting investors’ rights throughout the United States and internationally!  Please visit our website, www.secatty.com, post a comment, call (800) 732-2889, or email Mr. Pearce at pearce@rwpearce.com for answers to any of your questions about this blog post and/or any related matter.










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Robert Wayne Pearce

Robert Wayne Pearce of The Law Offices of Robert Wayne Pearce, P.A. has been a trial attorney for more than 40 years and has helped recover over $125 million dollars for his clients. During that time, he developed a well-respected and highly accomplished legal career representing investors and brokers in disputes with one another and the government and industry regulators. To speak with Attorney Pearce, call (800) 732-2889 or Contact Us online for a FREE INITIAL CONSULTATION with Attorney Pearce about your case.

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