Bradley Carl Reifler of New York New York a stockbroker formerly registered with Forefront Capital Markets (also former Chief Managing Officer of Forefront Capital Advisors LLC and Chief Executive Officer of Forefront Income Trust) is the subject of a Financial Industry Regulatory Authority (FINRA) National Adjudicatory Council Decision that affirmed a FINRA Hearing Panel Decision in which Reifler was barred from associating with any FINRA member in any capacity based upon findings of Reifler having failed to cooperate with FINRA personnel during an investigation into both his supervision of Forefront stockbrokers and the suitability of investments sold by stockbrokers under his command. In the Matter of Department of Enforcement v. Bradley C. Reifler Decision No. 2016050924601 (Sept. 30, 2019).

According to Decision, in 2016, FINRA discovered that an advertisement for a closed-end interval fund, Forefront Income Trust, was suggestive of non-accredited investors being able to have the same investment opportunities as accredited investors. The regulator discovered that shares of Forefront Income Trust were sold by Forefront Capital Markets stockbrokers, with one investor making a $10,000,000.00 purchase.

FINRA also discovered in 2016 that Reifler and Forefront Capital Holdings LLC were named as defendants in a civil action containing accusations against Reifler and Forefront of, among other things, breaching a fiduciary duty to the customer by investing the customer’s assets in loans that were made to Forefront affiliates; engaging in fraudulent activities including effecting investment transactions which stood to benefit Reifler personally; and submitting documentation which waived the plaintiff’s right to receive discounts of up to fifty percent on commissions.

Reifler subsequently became the subject of FINRA’s investigation, and was prompted to hand over information or documentation to the regulator in regard to the Forefront entities including Reifler’s position at Forefront Income Trust. He was specifically asked to discuss his supervision of Forefront Income Trust sales, and to furnish sales related documents. Reifler stalled in his response to FINRA, and when he finally responded, he failed to fully answer the regulator’s questions.

The Decision stated that Reifler reported to FINRA that he did not know about the due diligence undertaken by Forefront Capital Markets in reference to authorizations and sales of shares in Forefront Income Trust; and that he was not knowledgeable about any personnel within Forefront Capital Markets who performed due diligence. Also, the Forefront Income Trust CEO neglected to respond to FINRA’s questions on Forefront Capital Market’s determinations of suitability for those customers who purchased investments in Forefront Income Trust. Reifler was instructed to hand over documents in regard to suitability determinations or disclose where those documents could be located. Nothing was provided in response.

The Decision stated that Reifler was subsequently asked to testify before FINRA personnel in regard to Forefront Income Trust. FINRA sought his response to the allegations made by the plaintiff who brought the civil action alleging fraud. Reifler’s complete testimony was a requirement of complying with FINRA Rule 8210 but he failed to comply given his lack of a response to FINRA’s questions. Specifically, FINRA’s questions were not answered by Reifler because of his claim of FINRA lacking jurisdiction in the matter. He also failed to confirm with the regulator whether he solicited investments in Forefront Income Trust while he was employed by former securities broker dealer, Wilmington Capital Securities; and failed to disclose the identity of Forefront’s largest investor.

Reifler was later instructed by FINRA to make another appearance and provide recorded testimony. During this recorded testimony session, Reifler refused to respond to questions about the lawsuit against him. The Hearing Panel found Reifler’s failure to cooperate to be violative of FINRA Rules 2010 and 8210. FINRA’s National Adjudicatory Council affirmed, finding that Reifler failed to respond to FINRA’s questions which impeded the regulator’s investigation. In fact, the National Adjudicatory Council found Reifler’s objections to answering questions as completely meritless or otherwise invalid.

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Guiliano Law Group, P.C.

Our practice is limited to the representation of investors. Over the last three decades, we have recovered more than a hundred million dollars for more than 1,000 injured investors from all over the United States and several foreign countries. We accept representation purely on a contingent fee basis, meaning there is no cost to you unless we make a recovery for you. There is never any charge for a confidential consultation or an evaluation of your claim. For more information, contact us at (877) SEC-ATTY.

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