Robert Rivière’s Past
In September of 1976, Riviere joined FINRA. Heritage Financial Systems, Inc. (dba Heritage Financial Systems, LLC) (BD No. 133019) registered Riviere as a GSP, GSR, and in other capacities in April 2018. The firm terminated Robert Riviere’s association on December 12, 2019, citing her use of a personal email account for company work as the reason for filing a Uniform Termination Notice for Securities Industry Registration (Form U5). According to Article V, Section 4(a) of FINRA’s By-Laws, even though Riviere is not actively registered with nor affiliated with a FINRA member firm, she is nevertheless subject to FINRA’s jurisdiction.
The Financial Industry Regulatory Authority (FINRA) issued AWC No. TEX-467-AWC on March 30, 1987, finding that Robert Riviere, his member firm, and three other registered representatives had violated MSRB Rule G-8 by failing to prepare the trial balance and general ledger and securities receipt and delivery blotter; by failing to post accurate and current customer and broker ledgers; by failing to prepare a cash receipts and disbursements blotter as required by Exchange Act Rule 15c3-3 Jointly and severally, Riviere and the other respondents were fined $10,000 and given a reprimand.
Robert Riviere Report
As applicable, FINRA Rule 3270 states, “[n]o registered person may be an employee, independent contractor, sole proprietor, officer, director, or partner of another person, or be compensated, or have the reasonable expectation of compensation from any other person as a result of any business activity outside the scope of the relationship with his or her member firm, unless the registered person has provided prior written notice to the member, in such form as specified by the member.” When FINRA Rule 3270 is broken, FINRA Rule 2010 is likewise broken.
During the applicable period, registered representatives were not permitted to engage in any business activity outside the scope of their employment for remuneration without first notifying the firm in writing.
From September 2019 to December 2019, Riviere served as the company’s managing director. The date is set for November 20th, 2019.
Outside of his work with Heritage Financial Systems, Riviere signed a letter of engagement on behalf of his company with a third party to perform investing services. In November and December of 2019, for a fee of $5,000, Riviere modeled and analyzed the financial aspects of the purchase of cargo ships on behalf of a third party. Riviere did not provide the company advance notice in writing that he would be engaging in business outside of the company.
As a result, the Respondent violated FINRA Rules 3270 and 2010.
Sanctions, Penalties, and Other Repercussions
A $5,000 fine and a 30-day ban on working with any FINRA member in any capacity were also imposed.
The penalty must be paid before applying for relief from statutory disqualification owing to this or any other event or process, or upon reassociation with a member firm, whichever comes first.
Respondent expressly and freely waives any claim of inability to pay the monetary penalties imposed in this matter, both at the time of execution of this AWC and at any time thereafter.
Respondent is aware that a statutory disqualification, as defined in Article III, Section 4 of FINRA’s By-Laws, which incorporates Section 3(a)(39) of the Securities Exchange Act of 1934, would apply to him if he were barred or suspended from interacting with any FINRA member. During the term of the bar or suspension, he is not permitted to have any involvement with any FINRA member, including in an administrative or clerical position. Check out FINRA’s Rules 8310 and 8311.
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While employed by Heritage Financial Systems from September 2019 through December 2019, Riviere conducted unapproved outside business activities for which he was compensated without first giving the company advance written notice. As a result, Riviere broke FINRA’s Rules 3270 and 2010.
Financial Advisor Scam Warning Signs (Infographic).
Victims of Robert Riviere Can Get Help
You have grounds for a claim against Robert Riviere if you lost money due to his misrepresentation, an unsuitable investment, or an inappropriate investing plan. Then you can seek redress in court. In this field, fraud, malpractice, and neglect of duty cannot be tolerated. If you discover that your financial advisor or brokerage business is violating FINRA’s rules and regulations, you should report them immediately.
Financial advisers must offer the best investments and investment plans for their customers, as required by law and regulation. Their advice should be tailored to the client’s specific objectives and requirements. The brokerage firm that employs financial advisers also has a regulatory and legal obligation to monitor and supervise the activities of its Financial advisers. They should check whether or not the financial advisor is being manipulative or favors one investing strategy over another. The client or customer may be entitled to a complete or partial recovery of losses if the financial advisor and/or the brokerage firm breaches certain duties.
When making recommendations about investments or investment strategies, financial advisors should do so with their client’s best interests in mind. For an advisor’s recommendations to meet the standard of “reasonable basis suitability,” they must conduct a thorough assessment of the potential benefits and drawbacks of the investments and/or strategies they recommend.
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