Robert Todd Clark of Boston Massachusetts a stockbroker formerly employed by Moors Cabot Inc. has been barred from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity based upon consenting to findings that he failed to cooperate with a FINRA investigation into allegations of Clark’s unauthorized use of customer funds. Letter of Acceptance Waiver and Consent No. 2018057361101 (Sept. 21, 2018).

According to the AWC, in 2018, FINRA launched an investigation into accusations that Clark took money from a customer’s brokerage account without the customer’s consent, and proceeded to use the money for Clark’s own benefit.

FINRA apparently sent Clark a letter on July 23, 2018 seeking Clark’s recorded testimony to be provided for FINRA personnel according to Rule 8210. On August 21, 2018, Clark apparently responded to FINRA staff, revealing that he received the request from FINRA but would at no point be providing recorded testimony for FINRA personnel. The AWC stated that FINRA found Clark’s refusal to appear for testimony to be conduct violative of FINRA Rules 2010 and 8210. Consequently, Clark was barred by FINRA in all capacities.

Just prior to FINRA’s disciplinary action, on July 19, 2018, Moors Cabot discharged Clark based upon allegations that he accepted a customer loan without first seeking the firm’s permission; conduct violative of Moors Cabot policy. Prior to working at Moors Cabot, Clark was employed by Morgan Stanley Smith Barney. Yet, Morgan Stanley Smith Barney discharged Clark on May 15, 2013 founded on accusations that he exercised discretion in customers’ accounts.

FINRA Public Disclosure further reveals that a customer initiated investment related arbitration claim involving Clark’s activities was resolved for $41,250.00 in damages based upon allegations that while Clark was associated with Morgan Stanley, he breached his fiduciary obligations to the customer in reference to the customer’s equity investment holdings. NASD Arbitration No. 03-01507 (Nov. 30, 2006). Then, on May 20, 2013, a customer initiated investment related complaint concerning Clark’s conduct was settled for $34,000.00 in damages founded on accusations of unauthorized stock trading in the customer’s account while Clark was associated with Morgan Stanley.

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