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 Leon White II
OS/2009017798201
White recommended that a customer invest in non-listed real
estate investment trusts (REITs) and a tenants-in-common (TIC) interest in
undeveloped rural real estate without a reasonable basis to believe that the
recommendations were suitable for the customer based on the customer’s
financial status and investment objectives, and the customer’s need for
liquidity, preservation of capital, ready access to cash, and safety of
principal. The customer instructed White to sell the REITs
and White acknowledged receipt of the sell instructions and informed the
customer to expect to receive a check for the sale proceeds within one to two
weeks, but later refused to process the sell orders.White participated in the sale of TIC interests totaling $3,700,000,
outside the course or scope of his employment with his firm and collected
selling compensation of approximately $1,653,958 but failed to provide his firm
with prior written notice describing the proposed transactions.
Paul Leon White II: Barred