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Regulatory Sanctions

Ex-Wells Fargo Analyst Sanctioned for Undisclosed Material Conflicts of Interest

March 13, 2018

by Howard Haykin


What can you say about a research analyst who got “an offer he couldn’t refuse” and wouldn’t disclose? That the truth caught up with him.


Matthew Nemer agreed to a $20K fine and a 2-year suspension to settle FINRA charges that he published multiple research reports on a company while engaged in undisclosed employment discussions with that company


FINRA FINDINGS.    Nemer, a former research analyst with Wells Fargo Securities, had 18 years’ experience with 4 firms. While at Wells Fargo, he covered approximately 25 companies, including several retail furnishing companies including Company X.


In August 2015, Company X personnel informed Nemer that they were interested in hiring someone with a background like his. Nemer expressed interest in the job for himself and, over the span of 7 months, he exchanged emails with Company X personnel and had numerous meetings with senior management of Company X. In early February 2016, Nemer received a written employment offer, but the following month was told that his start date would be delayed a few months. Later in March, the employment offer was rescinded.


Throughout this period - from early August to late March - Wells Fargo published 5 research reports that Nemer authored. However:


  • Nemer never disclosed to Wells Fargo his employment discussions with and acceptance of an employment offer from the company to, in part, preserve his annual bonus from Wells Fargo - which he received in mid-March. 


  • Nemer never disclosed his material conflicts of interest in any of the research reports that he authored.


  • Nemer never disclosed that he had a financial interest in the company’s securities, as a result of his acceptance of an employment offer from the company that included issuance of restricted shares of company stock.


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

For details on this case, go to ...  FINRA Disciplinary Actions Online, and refer to Case # #2016051925301.