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Regulatory Sanctions

WWW: Church MInister/Registered Rep for Violating Sacred Oath - Gets Fined, Suspended

April 7, 2017

[Photo: DunHulk (Duncan Hull) / Flickr]


Being a Church Minister and a registered rep doesn’t cut much regulatory slack with FINRA - especially when the Minister is a broker who allegedly violated a sacred industry oath, by lying on a firm’s Annual Compliance Questionnaire. So, what can we take away from this FINRA case? Well, it’s critical for associated persons to keep their firms up-to-date on outside business activities – unless, of course, they're  violating firm policy, in which case you’d just be asking to be U5'd. The payoff for disclosing changing in circumstances is that the firm may actually give its permission – at least for an interim period.


Ricky Randon Moore, a resident of West Columbia, TX, agreed to a $30K fine and a 4-month suspension to settle FINRA charges that he participated in a church bond offering and did not provide prior written notice to his member firm concerning the outside business activities.


About the Respondent.    Moore entered the securities industry in 1994. He holds Series 7, 8, 31, and 63 securities licenses. He was associated with A.G. Edwards and LPL Financial from 1995 until 2009. He joined Commonwealth Financial Network in 2009, and operated his business - The Oak Financial Group - as an OSJ. Throughout his 4 years with Commonwealth, Moore was the minister of the Brazoria Church of Christ.


FINRA’s Specific Findings.    When Moore became registered through his firm, he requested and received the firm’s permission to act as a pulpit minister for a church and earn $30,000 in annual compensation. In his disclosure on the outside business activity form, Moore stated his duties and obligations as pulpit minister would be teaching and preaching, he would not spend any of his time on this activity in regular business hours, and none of this activity would be conducted in a FINRA-registered office. Further, the activity would not involve firm customers and Moore would not be involved in the church’s finances.


However, when the church began considering the possibility of issuing bonds to finance the construction of a new church building, Moore:


  • met with a registered rep employed by a B/D specializing in the issuance and marketing of church bonds;
  • attended meetings with the B/D;
  • gathered and sent financial information to the B/D about the church from his firm’s office;
  • incorporated the church so it could issue the bonds;
  • served as the president and director of the church for 34 days;
  • wrote draft language for a public letter to potential investors announcing an informational meeting about the bonds, reviewed the prospectus; and,
  • listened in on the informational meeting about the bond offering from the back of the room.


Moore never informed his employer about his expanded role or the fact that he was doing church business from his office. And, of course, he never noted any of the changes on the Annual Compliance Questionnaire.


This case was reported in FINRA Disciplinary Actions for March 2017.

For details on this case, go to … FINRA Disciplinary Actions Online, and refer to Case #2013038770901.