John David Sullivan Accused of Breaking FINRA Rules
Background
John David Sullivan, a financial professional, is currently facing a FINRA complaint. The complaint alleges that he did not furnish the documents and information requested by the American regulatory authority during their investigation. Additionally, Sullivan is registered as an investment adviser.
| Registration Dates | Firm Name | Branch Location | CRD# |
|---|---|---|---|
| 07/31/2020-11/16/2022 | INTERNATIONAL ASSETS INVESTMENT MANAGEMENT, LLC | COLUMBIA, MD | 144426 |
| 07/31/2020-02/04/2021 | GLOBAL ASSETS ADVISORY, LLC | COLUMBIA, MD | 300460 |
| 03/24/2017-07/27/2020 | LEXAURUM ADVISORS, LLC | Columbia, MD | 283653 |
| 09/01/2016-03/27/2017 | SUMMIT FINANCIAL GROUP INC | COLUMBIA, MD | 109485 |
| 03/17/2011-09/01/2016 | VSR ADVISORY SERVICES | COLUMBIA, MD | 14503 |
| 09/20/2010-03/18/2011 | NORTHWESTERN MUTUAL INVESTMENT SERVICES, LLC | COLUMBIA, MD | 2881 |
Allegations on John David Sullivan
John D. Sullivan violated FINRA Rules 8210 and 2010 by failing to furnish documents and information requested by FINRA on nine occasions.
Sullivan has been registered with FINRA through various brokerage firms since February 1998. In October 2018, he became registered as a General Securities Representative (GS) and Investment Company Variable Contract Products Representative (IR) with Brokers International Financial Services, LLC (CRD No. 139627).
However, the company fired him on July 23, 2020, for defying company policies by requesting personal loans from clients. Sullivan then registered with the Financial Industry Regulatory Authority again as a GS and IR through International Assets Advisory, LLC (CRD No. 10645) on July 31, 2020. He stayed with this firm until November 2, 2022, when he voluntarily terminated his association.
While Sullivan is no longer registered with FINRA, he still falls under their jurisdiction for this proceeding according to Article V, Section 4 of their By-Laws. This is because the complaint was filed within two years of his termination date and involves misconduct committed during his time as a registered representative. Additionally, Sullivan failed to respond to the regulatory authority’s requests for information during the two years after he ceased being registered with FINRA.
What do the FINRA Rules say?
Rule 8210 – Requests for Information, Testimony, and Inspections
- They may request oral, written, or electronic information from persons associated with their members or other entities subject to their jurisdiction.
- The staff may inspect and copy records of members and other entities subject to their jurisdiction.
- Refusing to provide information, or allowing inspections, as requested by FINRA is prohibited.
Rule 2010
- Standards of Commercial Honor and Just and Equitable Principles of Trade
- Persons associated with a FINRA member must maintain high standards of business ethics and conduct.
Reason behind rule violation
Sullivan breached Rules 8210 and 2010 by:
- neglecting to furnish documents as required by the First, Second, Third, and Fourth Tax Requests
- neglecting to supply documents and information in response to the first, second, Third, Fourth, and Fifth Medical Requests.
Conclusion
In conclusion, John D. Sullivan, a financial professional with a significant history in the industry, currently faces serious allegations of violating FINRA Rules 8210 and 2010. The core of the complaint revolves around Sullivan’s failure to provide requested documents and information during an investigation, a breach that occurred on multiple occasions.
Sullivan’s extensive employment history, spanning from 1998 to 2022, includes affiliations with various brokerage firms, each contributing to his experience as a General Securities Representative and Investment Company Variable Contract Products Representative. However, his termination from Brokers International Financial Services, LLC in 2020 for soliciting personal loans from clients marked a turning point in his career.
The subsequent registration with International Assets Advisory, LLC did not shield Sullivan from the repercussions of his alleged misconduct. Despite voluntarily terminating his association with the firm in November 2022, he remains subject to FINRA’s jurisdiction for the ongoing proceeding, as outlined in Article V, Section 4 of their By-Laws.
Sullivan’s failure to respond to multiple information requests and document submissions after leaving FINRA further compounds the severity of the situation. By neglecting his obligations under Rule 8210 and violating the overarching principles of business ethics outlined in Rule 2010, Sullivan has jeopardized his standing in the financial industry, potentially facing significant consequences pending the outcome of the FINRA complaint.
