- October 8, 2026
- LPL Financial
Rudy Anguiano (CRD# 5188950) was previously registered as a broker with LPL Financial LLC in Brea, California. According to his FINRA BrokerCheck report, FINRA has barred him from acting as a broker or associating with any FINRA member firm in all capacities. FINRA found that Anguiano converted $1,731,000 from two LPL customers by moving their money into the bank account of a limited liability company he solely owned and controlled.
Broker’s History
BrokerCheck shows that Anguiano entered the securities industry in 2007 and was registered with eight firms over roughly 19 years:
- WaMu Investments, Inc. (February 2007 to October 2008)
- LPL Financial Corporation (October 2008 to January 2010)
- U.S. Bancorp Investments, Inc. (March 2010 to September 2013)
- Wells Fargo Advisors, LLC (September 2013 to March 2016)
- Waddell & Reed (February 2016 to September 2020)
- Ameriprise Financial Services, LLC (September 2020 to April 2022)
- LPL Financial LLC (CRD# 6413) (April 2022 to December 2025)
- Alexander Capital, L.P. (January 2026 to July 2026)
He passed the Series 6, Series 7, Series 63, Series 66, and SIE examinations. BrokerCheck lists five disclosures: one regulatory action, one employment separation after allegations, two customer disputes, and one financial disclosure.
FINRA Bar (September 2026)
Anguiano submitted a Letter of Acceptance, Waiver, and Consent (AWC) (No. 2025088674601), and BrokerCheck reports that the bar took effect on September 25, 2026. Anguiano consented to the findings without admitting or denying them.
According to the AWC:
- The matter arose from FINRA’s review of the Form U5 that LPL filed on December 18, 2025, after terminating Anguiano.
- In July 2023, Anguiano became the sole owner of a limited liability company through which he engaged in an outside business activity.
- From July 2023 to August 2025, in five separate transactions, Anguiano received $1,528,000 from an LPL account belonging to one of his customers (Customer A) into the LLC’s bank account, which Anguiano controlled.
- From September 2024 to May 2025, in five separate transactions, Anguiano received $203,000 from an LPL account belonging to a second customer (Customer B) into the same LLC bank account.
- Neither customer authorized the transfers, and neither was aware that Anguiano was sending the funds to his LLC.
- FINRA found that Anguiano converted the funds in violation of FINRA Rules 2150(a) and 2010 and imposed a permanent bar from associating with any FINRA member in all capacities.
- The AWC states that LPL has reimbursed both customers in full.
The AWC’s charges are limited to conversion. FINRA did not charge Anguiano with violating its outside business activity rule (Rule 3270) or its private securities transaction rule (Rule 3280).
Termination by LPL Financial (November 2025)
BrokerCheck discloses that LPL discharged Anguiano on November 21, 2025. LPL reported that the termination followed allegations that he:
- Engaged in an outside business activity without prior notice and approval
- Participated in and directed clients to private investments
These are allegations reported by the firm on Anguiano’s termination disclosure and are not findings by a regulator or tribunal. According to the AWC, LPL filed amended Forms U5 in May 2026 disclosing the two customer complaints.
Customer Disputes
BrokerCheck lists two settled customer disputes. In each, the customer alleged that Anguiano accepted, and did not return, funds sent from the customer’s LPL account to an unapproved outside business for which Anguiano was the sole member. The disputes settled for $1,528,000 and $203,000, the same amounts FINRA found Anguiano converted from Customer A and Customer B.
Other Disclosures
BrokerCheck also reports a 2016 financial disclosure, a compromise with creditors that is listed as satisfied and released. After LPL terminated him, Anguiano registered with Alexander Capital, L.P. in January 2026. According to the AWC, that firm filed a Form U5 on July 8, 2026 disclosing his voluntary termination.
Outside Business Activities, Private Securities Transactions, and Selling Away
Although FINRA’s charges were limited to conversion, the conduct at the center of this case, an undisclosed outside business that received customer money, is precisely what FINRA’s outside activity rules are designed to bring to a firm’s attention. LPL also alleged that Anguiano directed clients to private investments, which is the core concern of FINRA’s private securities transaction rule.
Outside business activities (FINRA Rule 3270). Rule 3270 bars a registered person from working for another person, serving as its officer, director, or partner, or being compensated (or expecting to be compensated) by another person for any business activity outside the scope of his relationship with the firm, unless he has first given the firm prior written notice. Once notified, the firm must assess whether the activity would interfere with the representative’s responsibilities to the firm and its customers, or would be viewed by customers or the public as part of the firm’s business. It must then decide whether to condition, limit, or prohibit the activity. The firm must also determine whether the activity is really an outside business activity or a private securities transaction. Here, the AWC describes Anguiano’s LLC as the vehicle for an outside business activity, and LPL reported that he engaged in it without prior notice and approval.
Private securities transactions (FINRA Rule 3280). Rule 3280 prohibits an associated person from participating in any manner in a private securities transaction, meaning a securities transaction outside the regular course or scope of his employment, except as the rule allows. He must first give the firm written notice describing the transaction, his role, and whether he may receive selling compensation. Selling compensation is defined broadly and includes commissions, finder’s fees, and profit participation from any source. Where selling compensation is involved, the firm must approve or disapprove the transaction in writing. If it approves, it must record the transaction on its books and supervise it as if the firm itself had executed it; if it disapproves, the representative may not participate. Where there is no selling compensation, the firm must still acknowledge the notice in writing and may impose conditions.
Why this matters to investors: selling away. “Selling away” refers to a representative’s participation in investments the firm does not know about, has not approved, and does not supervise. The notice requirements of Rules 3270 and 3280 are how firms learn about that risk. When a representative’s outside business is never disclosed, money that customers send to it sits outside the firm’s records and review, and the customer loses the oversight that comes with investing through the firm. Common warning signs include an investment that does not appear on the brokerage firm’s account statements, the absence of any firm documentation about the investment, and transfers of money from a brokerage account to an outside company, particularly one connected to the financial advisor. Each of those features is present in the conduct FINRA describes in the Anguiano AWC.
Improper use of customer funds (FINRA Rules 2150(a) and 2010). The rules FINRA actually charged are Rule 2150(a), which prohibits any member or associated person from making improper use of a customer’s securities or funds, and Rule 2010, which requires adherence to high standards of commercial honor and just and equitable principles of trade. FINRA treats conversion, the intentional and unauthorized taking of another person’s property, as among the most serious violations a broker can commit, and a bar is the standard sanction.
The brokerage firm’s supervisory obligations (FINRA Rule 3110). Rule 3110 requires every member firm to establish and maintain a supervisory system reasonably designed to achieve compliance with the securities laws and FINRA rules, including reviewing its representatives’ outside activities and monitoring the movement of customer funds. Regulators treat an undisclosed outside business or securities transaction as a “red flag” that firms must investigate. FINRA’s AWC makes no findings against LPL. In selling-away and theft cases, however, firms often argue that the conduct was outside the scope of the representative’s employment, and investors may respond that the firm failed to supervise the representative or ignored red flags, such as repeated transfers out of a customer’s brokerage account to an entity controlled by the customer’s own advisor.
A pending rule change. On September 15, 2026, the SEC approved FINRA Rule 3290, which will replace Rules 3270 and 3280 with a single outside-activities rule focused on investment-related activity. FINRA has not yet announced the effective date, and Rules 3270 and 3280 remain in effect until it does. The conduct at issue in this case occurred under Rules 3270 and 3280.
What This Means for Investors
Registered representatives must disclose outside business activities to their firms, may not participate in private securities transactions without the firm’s knowledge and approval, and may never use customer funds for their own purposes. Firms, in turn, must supervise their representatives’ conduct. FINRA’s findings concern two customers, both of whom LPL has reimbursed. Investors who worked with Anguiano and who sent money to any company connected to him, invested in a private offering he recommended, or see transfers on their statements they do not recognize may wish to review their account records. These may involve selling away or broker theft. Depending on the facts, investors may be able to recover losses through FINRA arbitration.
The Wolper Law Firm, P.A. represents investors nationwide in securities litigation and arbitration on a contingency fee basis. Matt Wolper, the Managing Principal, is a trial lawyer who has handled more than 1,000 securities cases. Contact us at 800.931.8452 or mwolper@wolperlawfirm.com.
Matt Wolper is a trial lawyer who focuses exclusively on securities litigation and arbitration. Mr. Wolper has handled hundreds of securities matters nationwide before the Financial Industry Regulatory Authority (FINRA), American Arbitration Association (“AAA”), JAMS, and in state and federal court. Mr. Wolper has handled and tried cases involving complex financial products and strategies ranging from traditional stocks and bonds to options, margin and other securities-based lending products, closed/open-end mutual funds, structured products, hedge funds, and penny stocks. [