Andrew Gentiluomo (CRD #4975462) Has a Customer Dispute and Termination Disclosure on FINRA BrokerCheck
Andrew Gentiluomo (CRD #4975462) is a broker with a customer dispute and termination disclosure listed on FINRA BrokerCheck. We reviewed his BrokerCheck report on January 27, 2026. It reflects two disclosures. If you invested with Andrew Gentiluomo and have concerns, keep reading.
BrokerCheck link: BrokerCheck
BrokerCheck Report: BrokerCheck Report (PDF)
Employment Separation
Andrew Gentiluomo’s FINRA BrokerCheck Report reflects one employment separation after allegations. A summary is below:
On November 5, 2025, Equity Services, Inc. discharged Andrew Gentiluomo. The disclosure states he was involved with individuals’ investments in limited liability companies that were not made through the firm. It also states he executed a promissory note with a client to purchase her house.
Investor Disputes / Customer Complaints
Andrew Gentiluomo’s FINRA BrokerCheck Report reflects one customer dispute disclosure. A summary of the dispute is below:
On May 14, 2024, a customer complained about investments in two limited liability companies. The customer alleged Blue Sky violations, breach of fiduciary duty, constructive fraud, and common law conspiracy. They reported $200,000 in alleged damages. The case later became civil litigation in Montgomery Circuit Court in Christiansburg, Virginia, filed May 3, 2024. The dispute settled on August 29, 2025 for $124,285.71. Andrew Gentiluomo’s reported individual contribution was $62,142.86.
Rule Summary #1: FINRA Rule 3280 (Private Securities Transactions)
FINRA Rule 3280 requires a broker to give written notice to their firm before taking part in a private securities transaction. If the broker will receive compensation, the firm generally must approve and supervise the activity.
Rule Summary #2: FINRA Rule 3240 (Borrowing From or Lending to Customers)
FINRA Rule 3240 generally prohibits a registered person from borrowing money from or lending money to a customer. The rule allows limited exceptions, and it requires firm procedures and written approval when applicable.
Why This Matters to Investors (Regulation Best Interest)
Regulation Best Interest (Reg BI) is a U.S. securities regulation designed to strengthen the standard of conduct that broker-dealers owe to retail investors when making recommendations about securities transactions or investment strategies. Adopted by the U.S. Securities and Exchange Commission and effective as of June 30, 2020, Reg BI aims to enhance investor protection while preserving investor access to brokerage products and services.
Reg BI requires broker-dealers and financial advisors to act in the best interest of the retail customer at the time a recommendation is made, and not to place their own financial or other interests ahead of the customer’s. This represents a higher standard than the historical “suitability” requirement, which only required that recommendations be suitable, not necessarily optimal or conflict-free.
Reg BI is built around four key obligations:
- Disclosure Obligation – Broker-dealers must disclose material facts about the relationship and recommendations, including fees, scope of services, and conflicts of interest.
- Care Obligation – Recommendations must be made with reasonable diligence, care, and skill, considering costs, risks, and alternatives.
- Conflict of Interest Obligation – Firms must identify, disclose, and mitigate or eliminate conflicts, particularly those that create incentives to favor one product over another.
- Compliance Obligation – Firms must establish policies and procedures designed to ensure compliance with Reg BI as a whole.
Importantly, Reg BI applies at the recommendation level, not as a continuous duty like the fiduciary standard applicable to registered investment advisers. Still, it significantly narrows the gap by emphasizing cost considerations, conflict management, and investor-focused decision-making.
Overall, Regulation Best Interest seeks to promote transparency, improve the quality of investment recommendations, and reinforce trust between retail investors and broker-dealers in the U.S. securities markets.
Background Information (from BrokerCheck)
Based on his FINRA BrokerCheck report, Andrew Gentiluomo:
Is currently registered with Vanderbilt Securities, LLC and Consolidated Portfolio Review Corp.
Has passed the Securities Industry Essentials (SIE) exam. He has passed the General Securities Representative (Series 7) exam. He has also passed the Uniform Combined State Law (Series 66) exam.
Was previously registered with firms that include Equity Services, Inc., ESI Financial Advisors, and AXA Advisors, LLC.
Kurta Law Can Help
If you invested with Andrew Gentiluomo and you have questions about his BrokerCheck disclosures, Kurta Law can help you review your options. Call 877-600-0098 or email info@kurtalawfirm.com to speak with our team.
Helpful Resources: Selling Away | FINRA Rule 3240
Kurta Law has nearly 20 years of experience representing investors. We focus on securities arbitration and claims involving broker misconduct. We can review account records and explain potential next steps.