Our firm is investigating Raymond James Financial Services broker and investment advisor Thomas Christopher Rapp (CRD# 1792438) of Fort Lauderdale, Florida for potential investment-related misconduct arising from a pending customer dispute involving a fixed universal life insurance policy.
Thomas Christopher Rapp’s Financial Advisor Career History
Thomas Christopher Rapp (CRD# 1792438) has been in the securities industry since 1988 and is currently registered with multiple Raymond James entities in Florida.
- Current Registrations (since August 2025)
- Raymond James Financial Services Advisors, Inc. (CRD# 149018) – Investment Adviser Representative, based in Fort Lauderdale, Florida. Registered with this firm since August 11, 2025 (IA registration in Florida effective August 28, 2025).
- Raymond James Financial Services, Inc. (CRD# 6694) – General Securities Representative, also in Fort Lauderdale, Florida, registered since August 11, 2025.
- Prior Broker/Advisor Affiliations
- M Holdings Securities, Inc. (CRD# 43285) – Registered Representative and Investment Adviser Representative
- Brokerage registration (B): November 2004 – August 2025, Portland, Oregon
- Advisory registration (IA): December 2004 – August 2025, Fort Lauderdale, Florida
- 1717 Capital Management Company (CRD# 4082)
- Investment Adviser (IA): February 2002 – December 2004, East Hanover, New Jersey
- Broker (B): April 1995 – December 2004, Newark, Delaware
- Pruco Securities Corporation (CRD# 5685) – Broker (B): February 1988 – April 1995, Newark, New Jersey.
- M Holdings Securities, Inc. (CRD# 43285) – Registered Representative and Investment Adviser Representative
In addition to his brokerage and advisory work, Rapp has reported various outside business activities, including roles with Eagle Rock Wealth Management, Greenberg and Rapp Financial, Jones Lowry LLC, and several other entities, some of which involve insurance and financial-related services.
Thomas Christopher Rapp Fraud Allegations and Investor Complaints Explained
According to his FINRA BrokerCheck report, Thomas Christopher Rapp currently has one pending customer dispute involving the sale of a fixed universal life insurance policy while he was associated with M Holdings Securities, Inc.
Summary of the Pending Customer Dispute
- Type of Disclosure: Customer Dispute – Pending
- Reporting Source: Broker
- Employing Firm at Time of Events: M Holdings Securities, Inc. (CRD# 43285)
- Product Involved: Fixed Universal Life Insurance policy
- Core Allegations:
- The client alleges Rapp failed to exercise reasonable care and diligence in the sale of the policy.
- The complaint includes an alleged failure to disclose the characteristics, costs, and pricing of the policy.
- Policy Signature Date: October 27, 2021
- Date Notice/Process Served: December 11, 2024
- Alleged Damages: $1,234,482.59
- Litigation Status: Civil litigation pending
- Forum: Superior Court of New Jersey, Law Division – Morris County
- Docket/Case Number: MRS-L-002443-24
Bullet-Point Overview of the Disclosed Event
- Action:
- Consumer-initiated civil lawsuit alleging sales practice violations related to a fixed universal life insurance policy.
- Key Allegations:
- Failure to exercise reasonable care and diligence in recommending and selling the policy.
- Failure to adequately disclose policy characteristics, risks, costs, and pricing structure.
- Product Type: Insurance – fixed universal life
- Timeline:
- Policy signed: 10/27/2021
- Notice served: 12/11/2024
- Damages Sought: $1,234,482.59 in compensatory damages
- Status/Disposition:
- Matter is pending in state court; no final judgment, settlement, or dismissal has been reported as of the most recent BrokerCheck update.
As with all BrokerCheck disclosures, these are allegations only at this stage. The claims have not yet been adjudicated, and the dispute may ultimately be resolved in Rapp’s favor, dismissed, or settled without any admission of wrongdoing. Investors, however, should treat the disclosure as an important risk signal and carefully review their own transactions and policy documentation.
To obtain a copy of Thomas Christopher Rapp’s FINRA BrokerCheck report, visit this link.
Robert Wayne Pearce Is Committed to Recovering Your Investment Losses
In this context, FINRA Rule 2111 (Suitability) is particularly important. Rule 2111 requires brokers to 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—age, financial situation and needs, investment objectives, risk tolerance, time horizon, and other factors. When a broker recommends a complex product such as a fixed universal life insurance policy, that obligation includes understanding and explaining:
- How premiums, internal costs, and fees are structured
- How the policy’s cash value may perform under different assumptions
- The risks of underfunding or policy lapse
- Any surrender charges or penalties
The pending allegations against Rapp claim that he failed to exercise reasonable care and diligence in the sale of a fixed universal life policy and failed to disclose its characteristics, costs, and pricing. If proven, such conduct may constitute a violation of Rule 2111, because a recommendation cannot be suitable if the broker does not fully understand and communicate the product’s material risks, costs, and features to the customer. A broker who sells a high-cost, complex policy without ensuring it aligns with the client’s financial profile and objectives may be deemed to have breached his suitability obligations under this rule.
FINRA Rule 2010 (Standards of Commercial Honor and Principles of Trade) requires all FINRA members and their associated persons to observe high standards of commercial honor and just and equitable principles of trade. Rule 2010 is broad and often used by regulators and arbitrators to address misconduct that undermines investor trust, even if it does not fall neatly under a more specific rule.
In the dispute involving Thomas Christopher Rapp, the customer alleges that he failed to exercise reasonable care and diligence and did not adequately disclose the characteristics, costs, and pricing of a fixed universal life insurance policy. If a broker omits or glosses over key information about fees, cost structures, or policy mechanics—especially where the recommendation could result in large, long-term financial commitments—arbitrators and regulators may view that conduct as inconsistent with the high standards of honesty and fairness mandated by Rule 2010.
Thus, if the allegations are substantiated, Rapp’s conduct could be characterized as unfair and inconsistent with just and equitable principles of trade, giving investors a basis to argue that he and his firm violated FINRA Rule 2010 in addition to other more specific suitability and disclosure obligations.
FINRA Rule 2020 (Use of Manipulative, Deceptive or Other Fraudulent Devices) prohibits brokers from effecting any transaction or inducing the purchase or sale of any security by means of any manipulative, deceptive, or other fraudulent device or contrivance. While many life insurance products are not themselves “securities,” the principles of Rule 2020 are frequently cited in cases involving material misrepresentations or omissions in connection with investment-related products and strategies reported in FINRA’s regulatory system.
In the case of Thomas Christopher Rapp, the customer contends that he failed to disclose critical features and costs of a fixed universal life insurance policy while promoting it as suitable. If, for example, an investor was not told about high internal costs, the need for ongoing premium funding, or the risk that the policy could lapse without additional substantial payments, those omissions could be argued to constitute deceptive practices.
If a fact-finder concludes that Rapp intentionally or recklessly failed to disclose material information about the policy to induce the client to proceed with the transaction, the conduct could be viewed as violating FINRA Rule 2020 by effectively using an omission of material facts as a deceptive device. Even if the product itself is not labeled a “security,” the same fraudulent-device principles often guide the analysis in investor-protection cases involving complex, investment-like insurance products.
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.