William Forrest Winchester III (CRD #4404327, Chattanooga, Tennessee)

An AWC was issued in which William Forrest Winchester III (CRD #4404327) was barred from association with any FINRA member in all capacities. Without admitting or denying the findings, Winchester consented to the sanction and to the entry of findings that he borrowed more than $850,000 from his customers without notifying his member firms or obtaining their prior written approval. The findings stated that Winchester never disclosed to one of his firms that he had borrowed money from his customers. William Forrest Winchester III also falsely answered “no” on that firm’s annual questionnaires that asked, among other things, whether he had borrowed money from any customer. In addition, after one of Winchester’s customers passed away, he agreed to serve as a co-executor of the customer’s estate. Subsequently, Winchester borrowed money from the estate. Furthermore, Winchester signed a promissory note to the beneficiary of the estate, who was also his customer, to establish repayment terms for the funds he had borrowed. Winchester’s employing firm during this period prohibited its registered representatives from borrowing from customers. At the time William Forrest Winchester III was terminated from the firm, he was in the process of repaying the beneficiary the amounts borrowed pursuant to the terms of an agreement. The findings also stated that William Forrest Winchester III engaged in an undisclosed outside business activity (OBA). Winchester received $45,000 in compensation for his services as coexecutor of his customer’s estate. Winchester did not disclose to his employing firm his appointment as co-executor of his customer’s estate, and also failed to disclose that he was serving as co-executor of his customer’s estate when he associated with another firm. Winchester twice falsely represented on that firm’s compliance questionnaires that he was not, among other things, acting as an executor of any individual’s estate. The findings also included that Winchester entered into settlement agreements with customers without notifying his firm. William Forrest Winchester III did not disclose the promissory note that he signed to the beneficiary of his deceased customer’s estate to the firm and did not disclose a settlement agreement with one of his customers relating to $380,000 he had borrowed from the customer. (FINRA Case #2020065993801)