FINRA issued a complaint - not adjudicated yet - alleging that a Registered Principal for The Riderwood Group, a Maryland-based broker-dealer, willfully made misrepresentations and omissions of material fact to a customer in connection with the sale of securities. 

FINRA's complaint alleged that respondent Mitchell Fillet: 

1.  Prepared an offering document that contained numerous false representations about the purported business operations of the companies and failed to disclose the extensive criminal and civil record of the CEO of the companies.

2.  Knew, or was reckless in not knowing, these facts at the time he prepared the offering document.

3.  Directly or indirectly through the companies’ CEO, distributed the offering document to a customer in connection with his sale to the customer of units for the offerings.

4.  As his firm’s Chief Compliance Officer, was required to conduct a supervisory review of all variable annuity transactions. 

5.  Falsified new account forms, applications, acknowledgment forms, and related documents for variable annuity transactions that his firm executed for firm customers, and falsified the variable annuity documents by signing his name in those sections of the documents requiring his supervisory approval and backdating the documents to make it appear that he had conducted a timely supervisory review of the documents.

6.  Later provided the falsified documents to FINRA staff.   [FINRA Case #2008011762801, October]