May 16, 2022 – An AWC was issued in which Bennett Robert Zamani (CRD #6198730) was assessed a deferred fine of $27,500 and suspended from association with any FINRA member in all capacities for 14 months. Without admitting or denying the findings, Zamani consented to the sanctions and to the entry of findings that he failed to provide notice to his member firm that he was participating in an OBA, by owning and operating a company that offered subscription-based, investment content.
The findings stated that on the company’s website, which was established and operated by Zamani, the company maintained a blog, containing investment-related content, and maintained a publicly available YouTube channel, with investment-related videos. Zamani published content to the blog under his name or an alias and appeared in videos on the company’s YouTube channel. In addition, Zamani authored newsletters, containing investment-related content, which he periodically distributed to the company’s subscribers. While registered through the firm, Zamani earned approximately $360,000 from his activity with the company. In addition, Zamani submitted compliance questionnaires to the firm in which he falsely stated that he had fully disclosed his OBAs.
The findings also stated that in connection with his OBA, Bennett Robert Zamani (CRD #6198730, Saddle Brook, New Jersey) disseminated investment-related communications to the public, including firm customers that failed to comply with the content standards of FINRA because, among other things, they contained misleading and promissory statements and made recommendations without providing a sound basis for evaluating the facts. The findings also included that Zamani caused the firm to maintain incomplete books and records by using a personal text messaging application, which was not approved by the firm, to engage in business-related communications with firm customers. Zamani’s communications on the unapproved device and application included text messages related to securities recommendations, account performance, account fees, and market events.
In certain text messages, Zamani obtained personal confidential information from firm customers, such as driver’s license information, dates of birth, and social security numbers. In addition, Zamani submitted compliance questionnaires to the firm in which he falsely stated that he did not use personal electronic equipment to conduct firm business.
The suspension is in effect from May 16, 2022, through July 15, 2023. (FINRA Case #2020066847301)