Former Hilltop Securities Inc. Broker and Investment Advisor Rajesh Markan Barred

• June 18, 2026
• Hilltop Securities

Rajesh Markan (CRD#: 4553309) was previously both a registered Broker and Investment Advisor at Hilltop Securities Inc. in Dallas, TX.

Broker’s Background

Rajesh Markan entered the securities industry in 2002 and previously worked for IDS Life Insurance Company, Ameriprise Financial Services, Inc., Citigroup Global Markets Inc. and Merrill Lynch, Pierce, Fenner & Smith Incorporated.

Current And Past Allegations Of Conduct Leading To Investment Loss

According to publicly available records released by the U.S. Securities and Exchange Commission (SEC), On June 1, 2026, the United States District Court for the Northern District of Texas entered a final judgment as to Rajesh Markan in connection with the SEC’s civil enforcement action against him.

According to the SEC’s complaint, from at least 2015 through July 2024, Markan, while working as a registered representative of two dually-registered broker-dealers and investment advisers, solicited approximately ten of his brokerage customers to invest, collectively, approximately $2.9 million in a purported private equity fund. The complaint alleged that Markan told investors that a well-known New York private equity firm advised the fund and that their money would be tied up for six to twelve years, but he assured them that, ultimately, they could expect to make above-market returns. As alleged, none of these representations were true: the fund was fake and never existed, there was no association with the New York private equity firm, and Markan misappropriated most of the investors’ money for himself.

The final judgment, which follows the Court entering a bifurcated judgment as to the defendant on July 9, 2025, permanently enjoins Markan from violating Section 17(a) of the Securities Act of 1933 and Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder and permanently enjoins Markan from participating in the issuance, offer, purchase or sale of any security except for purchases or sales for his own personal accounts. In addition, the final judgment orders Markan liable for disgorgement in the amount of $2,305,025 and prejudgment interest in the amount of $132,776.15, with payment of those amounts deemed satisfied by the restitution of $2,445,000 ordered against Markan in a parallel criminal case, United States v. Rajesh Markan, Crim. No. 3:25-cr-145-N (N.D. Tex.).

The SEC’s investigation was conducted by Robert Boudreau and Keith Hunter of the SEC’s Fort Worth Regional Office. The SEC’s litigation was led by Tyson Lies and supervised by Keefe Bernstein. The SEC appreciates the assistance of FINRA, the FBI, and the U.S. Attorney’s Office for the Northern District of Texas.

 

For a copy of the SEC release, click here.

In addition, Rajesh Markan has been the subject of thirteen FINRA disclosures, including the following:

 

• July 2025 – The Securities and Exchange Commission (“Commission”) deems it appropriate and in the public interest that public administrative proceedings be, and hereby are, instituted against Rajesh Markan (“Markan” or “Respondent”). In anticipation of the institution of these proceedings, Respondent has submitted an Offer of Settlement (the “Offer”) which the Commission has determined to accept. The Commission finds that on July 9, 2025, a final judgment was entered by consent against Markan, permanently enjoining him from future violations of Section 17(a) of the Securities Act of 1933 (“Securities Act”) and Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) and Rule 10b-5 thereunder, as set forth in the judgment entered in the civil action entitled SEC v. Rajesh Markan, Civil Action Number [3:25-cv-01653], in the United States District Court for the Northern District of Texas, Fort Worth Division. The Commission’s complaint alleged that Markan made false and misleading statements and engaged in a fraudulent scheme to deceive in connection with the offer and sale of securities while working as a registered representative and investment adviser representative of two dually registered broker-dealers and investment advisers. Markan solicited approximately 10 of his brokerage customers from three separate states to invest, collectively, approximately $2.9 million in a purported private equity fund. Markan falsely told the investors that a well-known New York private equity firm advised the fund and provided investors a sham prospectus to describe the offering. In reality, the fund did not exist, the fund was not associated with the New York private equity firm, and Markan misappropriated most of the investors’ money. On or about March 31, 2025, Markan entered into a written plea agreement to plead guilty to a single count of securities fraud in violation of Title 15 of the United States Code, Sections 77q(a) and 77x before the United States District Court for the Northern District of Texas, in United States v. Rajesh Markan, Crim. No. 3:25-CR-145-N.
• June 2025 – Plaintiff SEC for its complaint against Defendant Rajesh Markan alleges that from at least 2015 through July 2024, Markan, while working as a registered representative of two dually-registered broker-dealers and investment advisers, solicited approximately ten of his brokerage customers to invest, collectively, approximately $2.9 million in a purported private equity fund. 
• February 2025 – Clients allege that they were solicited by their Financial Advisor to invest in an outside investment that was fraudulent. They also allege misappropriation of funds. Damage amount requested is $500,000.00.
• November 2024 – Client alleges that she was solicited by her Financial Advisor to invest in an outside investment that was fraudulent. She also alleges misappropriation of funds. Damage amount requested is $300,000.00.
• November 2024 – Client alleges that he was solicited by his Financial Advisor to invest in an outside investment that was fraudulent. He also alleges misappropriation of funds. Damage Amount Requested is $500,000.00.
• October 2024 – Client alleges failure to invest funds in October 2021. Settlement Amount was $33,119.30.
• October 2024 – Clients allege that they were solicited by their Financial Advisor to invest in an outside investment that was fraudulent. They also allege misappropriation of funds. Damage Amount Requested is $1,000,000.00.
• October 2024 – Clients allege that they were solicited by their Financial Advisor to invest in an outside investment that was fraudulent. They also allege misappropriation of funds. Damage Amount Requested is $1,200,000.00.
• October 2024 – Without admitting or denying the findings, Markan consented to the sanction and to the entry of findings that he refused to provide documents and information requested by FINRA as a part of its investigation into the circumstances giving rise to a Form U5 filed by his member firm. The findings stated that the Form U5 disclosed that Markan was under internal review at the firm for fraud or wrongful taking of property, or violating investment-related statutes, regulations, rules or industry standards of conduct. Resolution was Acceptance, Waiver & Consent(AWC) Bar (Permanent).
• September 2024 – Client alleges that she was solicited by her financial advisor to invest in an outside investment that was fraudulent. Settlement Amount was $255,000.00.
• September 2024 – Allegations that representative created a bogus hedge fund, bogus prospectuses and other materials to share with Claimants to solicit fraudulent investment. Damage Amount Requested is $420,000.00.
• August 2024 – Clients allege that they were solicited by their financial advisor to invest in an outside investment that was fraudulent. Settlement Amount is $365,000.00.
• October 2022 – Conduct involving failure to disclose a loan to a client. Termination type was voluntary resignation.

 

For a copy of Rajesh Markan’s FINRA BrokerCheck, click here.

We Help Investors Recover Investment Losses

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.

 

Reasonable basis suitability requires that a recommended investment or investment strategy be suitable or appropriate for at least some investors. Reasonable basis suitability requires an advisor to conduct adequate due diligence so that he or she can determine the risks and rewards of the investment or investment strategy.

 

Pursuant to FINRA Rule 3270, outside business activities in which Financial Advisors become involved must be disclosed.  FINRA Rule 3280 prohibits Financial Advisors from engaging in Private Securities Transactions, which are securities transactions that take place away from the employing brokerage firm.  The purpose of these rules is to ensure that Financial Advisors do not engage in selling away.  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.

 

Quantitative suitability requires a brokerage firm or financial advisor with actual or de facto control over a customer’s account to have a reasonable basis for believing that a series of recommended transactions – even if suitable when viewed in isolation – is not excessive and unsuitable for the customer when taken together in light of the customer’s investment profile. No single test defines excessive activity, but factors such as the turnover rate, the cost-equity ratio, and the use of in-and-out trading in a customer’s account may provide a basis for a finding that a member or associated person has violated the quantitative suitability obligation. 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.

The Wolper Law Firm represents investors nationwide in securities litigation and arbitration on a contingency fee basis.  Matt Wolper, the Managing Principal of the Wolper Law Firm, 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.