FINRA has filed a disciplinary complaint against investment adviser J. Randall Gladden of Securities Equity Group (“SEG”) stemming from allegations that he failed to inform SEG about his participation in two outside private placement funds.
According to the FINRA Complaint, Gladden “conceived of and participated in” the creation of the Church Development Fund, LLC, and its successor, the Church Fund LLC, and also had a managerial role with the funds. These funds made loans to churches for refinancing their existing real estate loans. Gladden solicited seven investors to invest in these private placements, who invested more than $2.1 million collectively.
Gladden, however, failed to inform SEG about his participation in these funds, which had not been approved for sale by SEG. “[O]n his 2011 and 2012 Compliance Certifications, Gladden falsely informed his Firm that he had not ‘engaged in any capital raising activities for any company, corporation or business entity” and failed to inform his Firm that he was serving as a principal member of the Funds’ respective managers. Gladden violated [FINRA Rules] by participating in private securities without providing prior written or other notice to his Firm and without receiving written approval from his Firm,” FINRA alleges in its Complaint.
The FINRA disciplinary proceeding is No. 2014038996201 and was filed December 28, 2015.
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