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Jeffrey Scott Nimmow of Merrimac, Wisconsin submitted a Letter of Acceptance, Waiver and Consent (AWC) to the Financial Industry Regulatory Authority (FINRA) in which he was barred for allegedly engaging in unapproved private transactions and for not possessing the proper registration in violation of NASD Rule 1031 and FINRA Rules 3280 and 2010.

From August 2015 to March 2018, Jeffrey Scott Nimmow was registered as an Investment Company Products/Variable Contracts Representative with Forest Securities Inc. (FSI). According to the FINRA findings, he engaged in the sale of promissory notes of more than $3 million to 18 different investors without the proper registration. The findings stated that Nimmow submitted a request to FSI to add sales of promissory notes to his outside business activities but failed to provide notice of each proposed transaction. In addition, FINRA stated that Nimmow sold $3,365,000 in the promissory notes and received approximately $177,937 in commissions without being qualified or registered to offer or sell promissory notes to his customers. Without admitting or denying FINRA’s findings, Nimmow consented to the sanctions and has been barred from association with any FINRA member in all capacities.

FINRA Rule 3280(b) states that “prior to participating in any private securities transaction, an associated person shall provide written notice to the member with which he is associated describing in detail the proposed transaction and the person’s proposed role therein and stating whether he has received or may receive selling compensation in connection with the transaction.” FINRA Rule 3280(e) defines generally a private securities transaction as any securities transaction outside the regular course or scope of an associated person’s employment with a member. NASD Rule 1031 (a) states that “all persons engaged or to be engaged in the investment banking or securities business of a member who are to function as representatives shall be registered as such with the NASD in the category of registration appropriate to the function to be performed as specified in Rule 1032. A violation of NASD Rule 1031 or FINRA Rule 3280 also constitutes a violation of FINRA Rule 2010.

Stockbrokers have been known to engage in many practices that may violate industry and firm rules, practices, and procedures.  In order to protect investors from stockbroker misconduct, FINRA rules require brokerage firms to establish and implement a supervisory system.  The implementation of these industry rules requires supervisors to monitor their employees to ensure compliance with federal and state securities laws, securities industry rules and regulations, and the brokerage firm’s own policies and procedures.  If broker-dealers and/or their supervisors fail to establish and implement these protective measures, they may be liable to investors for damages which flow from the broker’s misconduct. Therefore, investors who have suffered losses stemming from private transactions and/or other misconduct by their broker can file claims to recover damages against broker-dealers, like Forest Securities, which should consistently oversee its brokers’ activities in order to prevent the above-described misconduct.

Have you suffered losses in your Forest Securities account due to private transactions by your broker?  Was Jeffrey Scott Nimmow your stockbroker?  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 Forest Securities stockbrokers who may have engaged in broker 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 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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