SEC Brings An Enforcement Action Against Indianapolis Broker, Tamara Steele, For Selling Millions Of High-Risk Securities To Advisory Clients
The Wolper Law Firm, P.A. is currently investigating claims against Tamara Steele, a former Financial Advisor at Comprehensive Asset Management in Pendelton, Indiana. Tamara Steele has been in the securities industry since the 1990s and previously worked at Purshe, Kaplan Sterling Investments.
According to publicly available records released by the Securities and Exchange Commission (SEC), on September 14. 2018, it filed an enforcement action against Tamara Steele, alleging, among other things, that she was “selling approximately $13 million of high-risk securities to more than 120 advisory clients – many of whom are current or former teachers or other workers in public education – without disclosing that the firm and its owner stood to receive commissions of up to 18 percent from the sales.”
A copy of the SEC’s litigation press release can be accessed at https://www.sec.gov/litigation/litreleases/2018/lr24276.htm
In addition, Tamara Steele has a long history of regulatory and employment infractions, including numerous customer complaints, alleging sales practice violations:
- July 2018—Customer alleged “outside Business Activities, Selling Away and Private Securities Transactions, Unsuitable Investments, Negligent Account Management, Violations of the Indiana Securities Act.” The matter was settled for $65,000.
- June 2018—Customer alleged “outside Business Activities, Selling Away and Private Securities Transactions, Unsuitable Investments, Negligent Account Management, Violations of the Indiana Securities Act.” The matter remains pending.
- May 2018—Customer alleged “Outside Business Activities, Selling Away and Private Securities Transactions, Unsuitable Investments, Negligent Account Management, Violations of the Indiana Securities Act.” Alleged damages are $500,000 and the matter remains pending.
- January 2018—”Claimants allege that certain investments recommended by Ms. Steele were not suited to their investment objectives and were misrepresented.” The alleged damages are $95,000 and the matter remains pending.
Participation in outside business activities often leads to “selling away,” which is when financial advisors sell products and securities to clients that are not approved by the firm. The Financial Industry Regulatory Authority (FINRA) strictly prohibits financial advisors from “selling away” or selling securities and investments to clients that are not offered by the brokerage firm with which they are employed. For example, it is illegal and a violation of industry rules for a financial advisor to recommend or even suggest that a client invest in the financial advisor’s own business or a business operated by his or her friends or family. It is not necessary that the financial advisor earn any compensation for recommending an outside investment.
The purpose behind this prohibition is to ensure that a financial advisor only offers to sell securities that have been vetted by his or her employer brokerage firm through a rigorous due diligence process. Most brokerage firms have an approved list of investments, products, and research that can be provided or made available to clients. Any deviation by the financial advisor from the approved product list may constitute selling away.
To review a full copy of Tamara Steele’s FINRA disclosure report, click https://brokercheck.finra.org/individual/summary/3227494#disclosuresSection
Financial advisors have a legal and regulatory obligation to recommend only suitable investments that are appropriate for their clients’ needs and objectives. Their employing brokerage firm has a legal and regulatory obligation to supervise the Financial Advisors’ sales practices and dealings with clients. To the extent any of these duties are breached, the customer may be entitled to a recovery of his or her investment losses.
If you or someone you know was a customer of Tamara Steele and you experienced investment losses, please contact the Wolper Law Firm, P.A. at 800.931.8452 or by email at mwolper@wolperlawfirm.com to discuss your specific situation and the legal options available. The Wolper Law Firm, P.A. represents investors nationwide in securities litigation and arbitration.
Matt Wolper, the Managing Principal of the Wolper Law Firm, P.A., is a trial lawyer who has handled hundreds of securities cases during his career involving a wide range of products, strategies and securities. Prior to representing investors, he was a partner with a national law firm, where he represented some of the largest banks and brokerage firms in the world in securities matters.
Former Comprehensive Asset Management And Servicing, Inc. Broker, Tamara Steele, Barred By The Securities Exchange Commission
Tamara Steele (CRD # 3227494) was a Financial Advisor at Comprehensive Asset Management and Servicing, Inc. in Pendelton, IN. Tamara Steele has been in the securities industry since 1999 and previously worked at Purshe Kaplan Sterling Investments, American General Securities Incorporated, and Franklin Financial Services Corporation.
According to publicly available records released by the United States Securities and Exchange Commission (SEC), effective June 5, 2020, Tamara Steele was barred from associating as a broker or investment advisor or otherwise associating with firms that sell securities or provide investment advice to the public. Effectively, this means that Tamara Steele is unable to work as a registered Financial Advisor. It is alleged that from approximately December 2012 through October 2016, Tamara Steele fraudulently recommended and sold to her advisory clients over $13 million in extremely risky securities issued by a private company. According to FINRA’s summary of the SEC Sanction:
“The Commission’s complaint against Steele, the allegations of which Steele neither admits nor denies, alleged that from approximately December 2012 through October 2016, Steele fraudulently recommended and sold to her advisory clients over $13 million in extremely risky securities issued by a private company, Behavioral Recognition Systems, Inc. (“BRS”). The complaint also alleged that in violation of her fiduciary duties of loyalty and good faith, Steele failed to disclose to her clients that BRS had agreed to pay her commissions ranging from 8% to 18% of the funds raised for BRS. The complaint also alleged that Steele acted as a broker for BRS securities without registering with the Commission as such and illegally received hundreds of thousands of dollars in commissions for investments in BRS that she solicited from both advisory clients and other investors. The Commission’s complaint further alleged that, as part of the fraudulent scheme, Steele concealed her sales efforts on behalf of BRS from her own clients and from the broker-dealer with which Steele was associated at the time. The complaint also alleged that Steele (a) submitted false documents – including letters, invoices, and consulting agreements – to BRS claiming that her husband had provided the services, instead of her; (b) falsely attested to the broker-dealer that she had not engaged in any securities transactions “away from the firm”; and (c) secretly purchased BRS securities from a client using a nominee entity.”
For a copy of the SEC Sanction, click https://adviserinfo.sec.gov/individual/summary/3227494
In addition to the foregoing, Tamara Steele was the subject of thirteen customer complaints arising out of this same alleged misconduct. According to publicly available records released by the Financial Industry Regulatory Authority (FINRA):
• June 2019—”Sale of unregistered securities of BRS Labs while supervised by firm.” The matter settled for $18,700.00.
• November 2018—”Claimants allege that certain investments recommended by Ms. Steele were not suited to their investment objectives and were misrepresented.” The alleged damages are $60,000.00 and the matter remains pending.
• October 2018—”Claimants allege that certain investments recommended by Ms. Steele were not suited to their investment objectives and were misrepresented.” The alleged damages are $97,000.00 and the matter remains pending.
• October 2018—”Claimant allege that certain investments recommended by Ms. Steele were not suited to her investment objectives and were misrepresented.” The alleged damages are $55,000.00 and the matter remains pending.
• October 2018—”Claimants allege that certain investments recommended by Ms. Steele were not suited to their investment objectives and were misrepresented.” The matter settled for $1,181,449.00.
• October 2018—”Claimant allege that certain investments recommended by Ms. Steele were not suited to his investment objectives and were misrepresented.” The alleged damages are $23,671.72 and the matter remains pending.
• October 2018—”Claimants allege that certain investments recommended by Ms. Steele were not suited to their investment objectives and were misrepresented.”
The alleged damages are $25,000.00 and the matter remains pending.
• July 2018—”Outside Business Activities, Selling Away and Private Securities Transactions, Unsuitable Investments, Negligent Account Management, Violations of the Indiana Securities Act, Violation of Registered Investment Advisor Section of Indiana Securities Act, Sale of Unregistered and Non-Exempt Securities, Breach of Fiduciary Duty, Violations of FINRA Conduct Rules and NYSE Board Rules – Spring and Summer of 2014.” The matter settled for $65,000.00.
• June 2018—”Outside Business Activities, Selling Away and Private Securities Transactions, Unsuitable Investments, Negligent Account Management, Violations of the Indiana Securities Act, Violation of Registered Investment Advisor Section of Indiana Securities Act, Sale of Unregistered and Non-Exempt Securities, Breach of Fiduciary Duty, Violations of FINRA Conduct Rules and NYSE Board Rules.” The matter settled for $54,932.00.
• May 2018—”Outside Business Activities, Selling Away and Private Securities Transactions, Unsuitable Investments, Negligent Account Management, Violations of the Indiana Securities Act, Violation of Registered Investment Advisor Section of Indiana Securities Act, Sale of Unregistered and Non-Exempt Securities, Breach of Fiduciary Duty, Violations of FINRA Conduct Rules and NYSE Board Rules.” The matter settled for $130,498.00.
• March 2018—”Outside Business Activities, Selling Away and Private Securities Transactions, Unsuitable Investments, Negligent Account Management, Violations of the Indiana Securities Act, Violation of Registered Investment Advisor Section of Indiana Securities Act, Sale of Unregistered and Non-Exempt Securities, Breach of Fiduciary Duty, Violations of FINRA Conduct Rules and NYSE Board Rules.” The alleged damages are $124,757.53 and the matter remains pending.
• January 2018—”Claimants allege that certain investments recommended by Ms. Steele were not suited to their investment objectives and were misrepresented.” The matter settled for $44,500.00.
• July 2017—”Tamara Rae Steele was named in customers’ complaint that asserted the following causes of action: outside business activities and selling away; unsuitable investments and negligent account management; violations of the Indiana Securities Act; Violation of Registered Investment Advisor Section of Indiana Securities Act; sale of unregistered and non-exempt securities; breach of fiduciary duty; violations of the FINRA Conduct Rules and NYSE Board Rules; respondeat superior; and negligence and negligent supervision. The causes of action related to Claimants’ purchase of promissory notes, common stock, preferred stock, and stock warrants of Behavioral Recognition Systems, Inc. (“BRS Labs”). BRS Labs later became Giant Gray.”
Tamara Steele was terminated by Comprehensive Asset Management and Servicing, Inc. (CAMAS) after “Ms. Steele self-reported having participated in private securities transactions for multiple clients without prior notice and approval from CAMAS. Our internal review confirmed the facts of Ms. Steele’s self-report.”
For a copy of Tamara Steele’s CRD, click https://brokercheck.finra.org/individual/summary/3227494
FINRA strictly prohibits financial advisors from “selling away” or selling securities and investments to clients that are not offered by the brokerage firm with which they are employed. For example, it is illegal and a violation of industry rules for a financial advisor to recommend or even suggest that a client invest in the financial advisor’s own business or a business operated by his or her friends or family. It is not necessary that the financial advisor earn any compensation for recommending an outside investment.
The purpose behind this prohibition is to ensure that a financial advisor only offers to sell securities that have been vetted by his or her employer brokerage firm through a rigorous due diligence process. Most brokerage firms have an approved list of investments, products, and research that can be provided or made available to clients. Any deviation by the financial advisor from the approved product list may constitute selling away.
The Wolper Law Firm, P.A. represents investors nationwide in securities litigation and arbitration on a contingency fee basis. Matt Wolper, the Managing Principal of the Wolper Law Firm, P.A., is a trial lawyer who has handled hundreds of securities cases during his career involving a wide range of products, strategies and securities. Prior to representing investors, he was a partner with a national law firm, where he represented some of the largest banks and brokerage firms in the world in securities matters. We can be reached at 800.931.8452 or by email at mwolper@wolperlawfirm.com.