Keith Charles Moore

Sutter Securities Incorporated (CRD #30770, Irvine, California) and Keith Charles Moore (CRD #5191450, Newport, California) January 20, 2026 – The firm and Keith Charles Moore were named as respondents in a FINRA complaint alleging that the firm, while acting through one of its representative, willfully violated Reg BI when it failed to act in the best interests of a customer at the time a series of securities transactions were made. The complaint alleges that the representative recommended and effected 2,217 trades in accounts belonging to a retired, 89-year-old customer that was excessive and not in the customer’s best interests. In many instances, the representative did not consult the customer before placing trades in the customer’s accounts. The customer’s accounts incurred approximately $2.5 million in trading costs and more than $1.8 million in realized losses. The complaint also alleges that the firm and Moore, who served as the firm’s CEO and the representative direct supervisor, failed to supervise the representative by failing to identify and reasonably investigate and follow up on red flags indicating that the representative was engaged in potentially excessive and unsuitable trading. The representative told Moore that he was executing a replication strategy that was specifically mirroring the trades of a third-party asset manager in the customer’s account but the trading pattern he recommended and effected did not resemble the asset manager’s approach. It was a further red flag that the representative was systematically marking the transactions as “unsolicited” while he was purportedly implementing an investment strategy in the customer accounts while still charging the customer a substantial commission. Moore knew or should have known of the trading activity and the substantial commissions that the trading activity generated each month through his claimed review of the daily trade blotter and the monthly commission statements. The complaint further alleges that the firm failed to have a supervisory system, including WSPs, that was reasonably designed to achieve compliance with the suitability requirements related to excessive trading. The WSPs failed to provide guidance for identifying such activity and did not identify any metrics for evaluating potential excessive trading or require designated principals to employ any metrics in their supervisory review. Beyond the WSP failures, the firm’s supervisory system did not use metrics, exception reports, or surveillance tools to identify potential excessive trading, failed to implement any system ensuring required suitability reviews were conducted, and provided no procedures or system for responding to potential excessive trading once identified. In addition, the complaint alleges that the firm willfully violated Reg BI by failing to establish, maintain, and enforce written policies and procedures reasonably designed to achieve compliance with Reg BI’s Care Obligation regarding excessive trading. Moreover, the complaint alleges that the firm failed to establish, maintain, and enforce a supervisory system, including WSPs, reasonably designed to supervise the electronic communications of its registered representatives. The firm’s WSPs failed to reasonably address email review supervision or provide substantive guidance on the review process. In addition, the firm’s system to review email was unreasonable because it relied on fragmented, undocumented, ad hoc reviews by multiple individuals without standardization procedures, supervision tools, or designated oversight responsibility. (FINRA Case #2021071987902) If you have suffered losses as a result of Keith Charles Moore's act and/or actions, we would like to hear from you. We are currently investigating claims on behalf of clients who have suffered significant losses in their portfolios that are managed by Keith Charles Moore. The Schwartz Law Firm represents investors in claims against financial advisors and their firms. If you have questions about your potential claim or need assistance from an investment fraud lawyer, please contact us at 866-330-6707 or email Matthew Schwartz directly at mschwartz@tslfirm.com.