Arete Wealth Management Raymond Lawrence Lent Discloses Two SEC Orders and Six Settled Customer Claims

• October 19, 2026
• Arete Wealth Management

Raymond Lawrence Lent (CRD# 817645) of San Rafael, California is an investment adviser representative with The Putney Financial Group LLC and a registered representative with Arete Wealth Management, LLC. According to his FINRA BrokerCheck report and SEC IAPD report, the SEC has entered two orders against Lent’s advisory business. In May 2024, the SEC ordered him to pay more than $1 million for failing to disclose conflicts of interest in recommending commission-paying variable annuities and selecting revenue-sharing money market funds. His record also discloses five FINRA arbitration claims over GWG Holdings L Bonds, which his former broker-dealer settled for a combined $539,706.82.

Broker’s History

BrokerCheck shows that Lent entered the securities industry in 1976 and has about 50 years of experience. He has been registered with Arete Wealth Management, LLC (CRD# 44856) since December 2024, at a branch at 100 Smith Ranch Road in San Rafael. He has been registered as an investment adviser representative of The Putney Financial Group LLC (CRD# 111639) since July 2024. His prior broker-dealer registrations include:

• Portsmouth Financial Services (CRD# 13980), San Rafael, CA (July 2010 to December 2024)
• McClurg Capital Corporation (CRD# 16798), San Rafael, CA (July 1998 to July 2010)
• Park Avenue Securities LLC (CRD# 46173), New York, NY (May 1999 to November 1999)
• Guardian Investor Services Corporation (CRD# 6635), New York, NY (April 1998 to May 1999)
• Centaurus Financial, Inc. (CRD# 30833), Anaheim, CA (August 1997 to July 1998)
• MONY Securities Corp. (CRD# 4386), New York, NY (January 1976 to August 1997)

Lent founded Putney and is its managing member. BrokerCheck also lists him as a part owner, director, and Chairman of the Board of Portsmouth, the broker-dealer affiliated with Putney. Arete Wealth Management acquired Portsmouth in May 2024, and Portsmouth’s business now operates as an Arete branch.

Lent has passed the Series 1, Series 7, Series 24, Series 63, Series 65, and SIE examinations. His disclosed outside business activities include a fixed insurance sales business (Risk Management Advisors, LLC), a business consulting and recruiting firm (Legacy Bridge Financial LLC), and a rare coin and print resale business. BrokerCheck reports nine disclosure events: two regulatory actions and seven customer disputes. None is currently pending.

SEC Order: Variable Annuities and Cash Sweep Funds (May 2024)

On May 20, 2024, the SEC entered a settled order against Lent, doing business as The Putney Financial Group, Registered Investment Advisors (Advisers Act Release No. 6608; Admin. Proc. File No. 3-21943). Lent consented to the order without admitting or denying its findings. According to the order and the SEC’s summary:

• From at least April 2016 through October 1, 2021, Putney recommended commission-based variable annuities to its advisory clients. The insurers paid Portsmouth an upfront commission averaging 6.8% of the amount invested, and Portsmouth paid Lent about 92% of that commission.
• For most of those annuities, the same insurer offered a fee-based version with the same features, no sales commission, and lower ongoing fees. Putney consistently recommended the commission-paying version and did no analysis of whether the fee-based version was in its clients’ best interest.
• From at least April 2016 through April 2021, Putney swept clients’ uninvested cash into money market funds that paid revenue sharing to Portsmouth. Lower-cost funds in the same category, which at times paid higher yields, were available through the clearing firm.
• Putney did not disclose the revenue sharing at all until September 2019, after an SEC examination. The disclosure it then added stated that the firm selected the money market fund paying clients the most interest. The SEC found that statement false and misleading.
• Putney also failed to adopt and implement written compliance policies and procedures reasonably designed to prevent these violations.

The SEC found that Putney willfully violated Section 206(2) of the Investment Advisers Act of 1940 and Section 206(4) and Rule 206(4)-7 thereunder. Lent was censured, ordered to cease and desist, and ordered to pay disgorgement of $707,129.58, prejudgment interest of $183,236.60, and a civil penalty of $175,000. The undertakings required him to correct disclosures, evaluate moving existing clients into lower-cost annuities and money market funds, and send a copy of the order to affected clients. BrokerCheck reports that the order is based on violations of laws that prohibit fraudulent, manipulative, or deceptive conduct.

In February 2025, the SEC created a Fair Fund to distribute the $1,068,800.53 that Lent paid to harmed investors. The order set January 9, 2026 as the deadline for the SEC staff to submit a proposed plan of distribution.

SEC Order: Mutual Fund Share Classes (March 2019)

On March 11, 2019, the SEC entered a settled order against Lent, doing business as The Putney Financial Group (IA Release No. 5194; Admin. Proc. File No. 3-19097). It was one of 79 orders issued under the SEC’s Share Class Selection Disclosure Initiative, under which advisers self-reported. According to BrokerCheck, the SEC found that from January 1, 2014 to June 7, 2018, Putney placed advisory clients in mutual fund share classes that charged 12b-1 fees when lower-cost share classes of the same funds were available. The 12b-1 fees went to Putney’s affiliated broker or its associated persons, and Putney did not disclose the conflict in its Form ADV.

The SEC found willful violations of Sections 206(2) and 207 of the Advisers Act. Lent was censured, ordered to cease and desist, and ordered to pay $43,034.83 in disgorgement and prejudgment interest to affected clients. Consistent with the initiative’s terms, the SEC imposed no civil penalty. Lent’s statement on BrokerCheck says Putney itself received none of the 12b-1 fees, which were paid to Portsmouth, and that Putney asked Portsmouth to refund them to clients with interest.

Customer Disputes (2023 to 2024)

Between February and April 2023, five FINRA arbitration claims were filed against Portsmouth over GWG Holdings L Bonds that Lent sold. Each claim identified Lent as the registered representative or agent. Together the claims alleged at least $1,608,000 in damages, and Portsmouth settled all five between March and May 2024 for $539,706.82.

FINRA Case No.	Filed	Claims Alleged	Damages Alleged	Settlement
23-00862	Apr. 7, 2023	Negligence, breach of fiduciary duty and contract, misrepresentation	$300,000	$145,000.00
23-00652	Mar. 17, 2023	Failure to conduct reasonable due diligence, lack of disclosure, overconcentration	$125,000	$20,591.14
23-00427	Feb. 17, 2023	Improper recommendation, failure to conduct reasonable due diligence	$591,000	$114,349.35
23-00405	Feb. 16, 2023	Misrepresentation, failure to conduct reasonable due diligence, lack of disclosure	$377,000	$228,843.38
23-00313	Feb. 8, 2023	Misrepresentation, failure to conduct reasonable due diligence	$215,000	$30,922.95

Lent was not named as a respondent in these claims and did not contribute to the settlements. His statement on each disclosure says he continues to deny all allegations.

Other Customer Disputes

• Alternative investments (FINRA No. 25-00252, settled November 2025 for $32,500): A client alleged that Lent sold an unsuitable alternative investment while he was with Portsmouth. The claim was served in February 2025 and did not specify a damages amount. Lent did not contribute to the settlement.
• Arbitration award (FINRA No. 10-03886, February 2012, $23,000): A client of McClurg Capital Corporation alleged unsuitable recommendations of annuities, stocks, and mutual funds from April 2007 to February 2010. Lent was a named party. At the close of the hearing, the claimant requested between $153,981.55 and $196,070.07. The panel awarded $23,000, and Lent contributed $11,500. His statement notes that the award was a split decision, with the panel chair dissenting.

Settlements are not admissions of wrongdoing.

Conflicts of Interest, Unsuitability, and the Applicable FINRA Rules and Legal Standards

Lent’s record involves two kinds of conduct: an adviser steering clients into products that paid his affiliated broker-dealer, and sales of a speculative, illiquid bond that later defaulted. Each implicates a distinct set of standards.

Fiduciary duty of an investment adviser (Advisers Act Section 206). Investment advisers owe their clients a fiduciary duty of loyalty and care. The duty of loyalty requires full and fair disclosure of conflicts of interest, so the client can give informed consent. Saying an adviser “can receive” compensation is not enough when it actually does. The duty of care requires advice in the client’s best interest, which includes considering lower-cost alternatives that are reasonably available. As the 2024 order notes, a Section 206(2) violation does not require intent to defraud and may rest on negligence. An adviser that recommends a commission-paying product over an identical lower-fee version, without analysis or disclosure, commits a breach of fiduciary duty.

Compliance policies (Advisers Act Rule 206(4)-7). Registered advisers must adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. The SEC found Putney had none addressing its variable annuity and cash sweep conflicts.

Deferred variable annuities (FINRA Rule 2330). When a broker-dealer representative recommends a deferred variable annuity, Rule 2330 requires a reasonable basis to believe the customer has been informed of its material features, including surrender charges, mortality and expense fees, and investment advisory fees. The representative must also reasonably believe the customer would benefit from the annuity’s features and that the particular product is suitable. A registered principal must review and approve the transaction.

Suitability and best interest (FINRA Rule 2111 and Regulation Best Interest). For recommendations made before June 30, 2020, FINRA Rule 2111 required reasonable-basis, customer-specific, and quantitative suitability. Reasonable-basis suitability requires reasonable diligence to understand a product’s risks before recommending it. Since June 30, 2020, Regulation Best Interest has required broker-dealers to act in a retail customer’s best interest and to disclose and mitigate conflicts of interest. The GWG claims alleged failure to conduct due diligence, overconcentration, and misrepresentation. Those allegations go directly to these obligations.

Misrepresentations and omissions (FINRA Rules 2020 and 2010). Rule 2020 prohibits manipulative, deceptive, or fraudulent devices. Rule 2010 requires high standards of commercial honor. Misstating a bond’s risks, or failing to disclose its illiquidity and default risk, may violate both.

The brokerage firm’s supervisory obligations (FINRA Rule 3110). Rule 3110 requires each member firm to reasonably supervise its representatives. Supervision of a representative who is also a co-owner and Chairman of the Board of the firm raises questions about independence. Portsmouth, not Lent, was the respondent in the GWG claims, which is common: investors often pursue the broker-dealer for failure to supervise.