The following context has been submitted to and accepted by the applicable state regulatory authorities. Each item represents my personal account of the circumstances surrounding each disclosure on my Form U4.
Neither Richard Siminou nor Siminou Wealth Management has ever been investigated by, involved with, or the subject of any legal action initiated by any outside law firm on behalf of clients. No law firm has ever represented any client in a matter against Richard Siminou or Siminou Wealth Management. Any online content, links, or postings suggesting otherwise are factually incorrect and have no basis in any complaint, legal proceeding, or regulatory referral. Such content does not reflect the experience of our clients and should not be relied upon.
Arbitration — Former BD Newbridge Corp.
May 11, 2023 · Alternative investment dispute
This matter involved an alternative investment approved on the Newbridge platform. The client was knowledgeable and suitable, with experience in equities and alternative investments. The client had sold a second home and wanted to invest in alternatives based on prior success. I recommended Pepsi and Apple stock, but the client declined equities due to personal losses during the financial crisis. The order was unsolicited — the Radfords were solicited directly by the Coldspring Group.
Newbridge elected to settle the matter, which was properly their case. I did not personally participate in the settlement and no personal funds were paid by me. While the case was directed at Newbridge, I was the broker of record and Newbridge chose to mark up my U4.
Customer Dispute — Newbridge U4 Error
August 31, 2023 · Erroneously reported
Newbridge erroneously placed this complaint on my U4. The arbitration named three claimants and three brokers. I was subsequently released — a fact now reflected on my BrokerCheck record. No funds were paid by me to any claimant.
Newbridge did not contact me before marking up my U4 and was unaware I had been released. Of the three clients named, I only worked with one — the Wands client — and had no relationship with the other two.
Regulatory Final — FINRA Settlement
August 31, 2023 · No admission of wrongdoing
This settlement was reached without any admission of wrongdoing on my part. The affected clients did not initiate complaints — FINRA solicited and pursued this matter independently. I received a brief suspension only on my broker license (not financial advisory) from September 18, 2023 through January 17, 2024, and paid restitution to two clients targeted by FINRA.
Both clients were inherited from other brokers and I worked with each for approximately one year. FINRA isolated December 2018 — a period when the S&P 500 corrected approximately 10% — and stated on record to my attorney that they were examining only the period when accounts declined, not periods of positive performance or overall portfolio results. The clients saw a financial opportunity at my expense and agreed to cooperate with FINRA.
Importantly, the settlement contains no finding that I acted willfully or with intent to harm any client. Upon completion of the suspension, I was permitted to return to the broker-dealer business without restriction. I have since remained focused on the financial investment advisory side of my practice.
Maryland Registered Representative License Revocation
September 18, 2023 · Procedural matter — no finding of misconduct
Maryland revoked my registered representative license as a result of my failure to respond timely to their communications. This was a procedural matter — not a finding of misconduct or any substantive violation. I misunderstood Maryland's process and relied on guidance from my firm's compliance department, to whom the Maryland correspondence was also addressed, which contributed to the delayed response.
I am actively working to reopen communications with Maryland and pursue reinstatement of my license. This matter has no impact on my ability to serve clients in my current capacity as a registered investment adviser.