Investment Adviser Barred for Marketing Program Involving Unsuitable Trading

Based on a prior proceeding brought by the State of Ohio Department of Commerce, Division of Securities, the SEC found that respondent operated a program called the Controlled Asset Transfer System (CATS), which was marketed to insurance agents who sought to have their clients or prospective clients liquidate existing securities in order to sell the clients insurance products. Respondent allegedly advised each insurance agent to use the CATS program to avoid acting as a securities salesperson without a license and, through the program, liquidated clients’ securities without sufficient information and without conducting a reasonable inquiry into whether such liquidations were suitable for these investors.