Investment Advisor Bradley Holts Subject of SEC Proceedings Alleging Misappropriation

Bradley Holts (CRD#: 5819398) was a previously registered broker and investment advisor.

Broker’s Background

He entered the securities industry in 2010, and has previously worked for World Capital Brokerage, Inc.; Supreme Alliance, LLC; Capital One Investing, LLC; and Edward Jones.

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), in October 2023, the Securities and Exchange Commission (“Commission”) deemed it appropriate and in the public interest that public administrative proceedings be instituted pursuant to Section 15(b) of the Securities Exchange Act of 1934 (“Exchange Act”) against Bradley M. Holts (“Respondent” or “Holts”). The Division of Enforcement alleges that between February 2021 and May 2021, Holts misappropriated $186,382 from three elderly investor customers (the “Three Investors”). Holts falsely told these investors that he would invest their money in securities of mutual funds offered by the investment management firm Invesco Ltd. (“Invesco”). In fact, Holts stole the investors’ money and used the money to pay personal expenses, including for clothing, tanning salons, adult and dating websites, and a divorce lawyer. Holts has not repaid the Three Investors. On February 27, 2023, the Commission filed a complaint in the United States District Court for the Eastern District of Texas, Beaumont Division, against Holts alleging that his conduct violated Section 17(a) of the Securities Act of 1933 (“Securities Act”), and Section 10(b) of the Exchange Act and Rule 10b-5 thereunder. See SEC v. Bradley Morgan Holts, Case No. 1:23-cv-00081 (E.D. Tex.). Holts did not respond to the Commission’s complaint.

On October 11, 2023, the district court entered a final judgment by default against Holts that (1) permanently enjoins him from violations of Section 17(a) of the Securities Act, and Section 10(b) of the Exchange Act and Rule 10b-5 thereunder, (2) orders Holts to pay disgorgement in the amount of $186,382 plus prejudgment interest in the amount of $18,005.31, and (3) imposes a civil penalty on him in the amount of $186,382.

In addition, Bradley Holts has been the subject of several other disclosures, which include the following:

  • July 2021—“Pursuant to FINRA Rule 9552(h) and in accordance with FINRA’s Notice of Suspension and Suspension from Association letters dated July 28, 2021 and August 23, 2021, respectively, on November 1, 2021, Holts is barred from association with any FINRA member in all capacities. Holts failed to request termination of his suspension within three months of the date of the Notice of Suspension; therefore, he is automatically barred from association with any FINRA member in all capacities.”
  • July 2021—“Bradley Holts failed to respond to multiple requests for information in connection to a FINRA matter which is in violation of World Capital Brokerage, Inc’s Supervisory Procedures in connection with requests made by FINRA. In the FINRA request dated July 8, 2021, Mr. Holts was informed that he is in violation of FINRA Rule 8210.” Bradley Holts was discharged from World Capital Brokerage, Inc.
  • October 1997—“Criminal Charges: Retaliation.” The charges were dismissed.

For a copy of Bradley Holt’s SEC Advisor disclosures, 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.


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.


Customer-specific suitability requires that a member or associated person have a reasonable basis to believe that the recommendation is suitable for a particular customer based on that customer’s investment profile. Among the criteria that a financial advisor must evaluate to satisfy his or her customer-specific suitability obligations include the investor’s age, tax status, time horizon, liquidity needs, and risk tolerance; a client’s other investments, financial situation and needs, investment objectives, and any other information disclosed by the customer should also be considered.


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.

Attorney Matthew Wolper

Attorney Matthew WolperMatt 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. [Attorney Bio]