Skip to main content

Mark Finelli Comment On Regulatory Notice 25-05

Ms. Jennifer Piorko Mitchell Office of the CorporateSecretary FINRA

1735 K Street

Washington, DC 20006

Re: Request for Comment on Regulatory Notice25-05

Dear Ms. Mitchell,

Asan owner of a Registered Investment Advisory (RIA) firm having registered representatives at a member firm that is independent and not affiliated in any manner with my RIA firm, I strongly object to the newly proposed Rule 3290 in Regulatory Notice 25-05.

2020065124801 Thomas A. Vigil CRD 3269058 AWC lp (2025-1748564404660).pdf

From June 2019 to February 2020, Vigil recommended 10 unsuitable L-share variable annuity exchanges to nine customers, and two unsuitable variable annuity purchases to two customers, without a reasonable basis to believe that the recommendations were suitable. In connection with these transactions, Vigil made negligent misrepresentations and omissions of material fact about the variable annuities’ costs on transaction documents. Vigil also forged a customer’s variable annuity application by photocopying the customer’s signatures from a different document.