NOTE: Stipulations of Fact and Consent to Penalty (SFC); Offers of Settlement (OS); and Letters of Acceptance Waiver, and Consent (AWC) are entered into by Respondents without admitting or denying the allegations, but consent is given to the described sanctions & to the entry of findings. Additionally, for AWCs, if FINRA has reason to believe a violation has occurred and the member or associated person does not dispute the violation, FINRA may prepare and request that the member or associated person execute a letter accepting a finding of violation, consenting to the imposition of sanctions, and agreeing to waive such member's or associated person's right to a hearing before a hearing panel, and any right of appeal to the National Adjudicatory Council, the SEC, and the courts, or to otherwise challenge the validity of the letter, if the letter is accepted. The letter shall describe the act or practice engaged in or omitted, the rule, regulation, or statutory provision violated, and the sanction or sanctions to be imposed.

Paul Michael Tavelman
AWC/2008015108101

Tavelman recommended an unsuitable concentration of high-risk investments for an estate account. As a result of Tavelman’s investment choices, approximately 50 percent to 95 percent of the estate account’s investments during the relevant period included one or more high-risk income funds.

Tavelman recommended the transactions without having reasonable grounds for believing that such transactions were suitable for the customer in view of the nature of the account and the customer’s financial situation, investment objectives and needs. The recommendations were unsuitable in that the executor of the estate account was seeking conservative, growth investments for the account without risk to principal, and the estate account suffered losses as a result of Tavelman’s unsuitable recommendations.

Tavelman exercised discretion in the estate account without the executor’s prior written authorization and his member firm’s written acceptance of the account as discretionary.

Paul Michael Tavelman : No fine in light of financial status; Ordered to pay $7,000 restitution to customer; Suspended 30 days

Tags: Estate