On November 1, 2018, an OHO (Office of Hearing Officers) decision became final and James Randall Clay has been barred for allegedly engaging in private securities transactions and misrepresenting facts to his member firm and FINRA in violation of FINRA Rules 3270 and 2010.
James Randall Clay was employed with U.S Bancorp from August 2012 until December 2013 when his firm filed a Uniform Termination Notice of Securities Registration (“Form U5”) for violating the firm’s Code of Ethics. FINRA stated that Clay engaged in private securities transactions without written notice or approval from his member firm. On December 7, 2013, while associated with U.S. Bancorp, he started a company under the name “Clay Enterprises, LLC” which he intended to use to manage rental properties. According to FINRA, Clay purchased real estate from an elderly customer from his member firm under terms that only benefited himself. Clay allegedly drafted and signed an agreement to purchase the customers property for $1 million, with the customer financing the amount and borrowed an additional $500,000 to fund the down payment on the property. In addition, Clay established a limited liability company to manage the rental and began collecting rent. The findings stated that Clay never provided notice to his member firm and when the customer’s family complained, he claimed he was not the purchaser and only helped his sister purchase the property. Continue Reading