FINRA Suspends Maxim Tulupnikov Suspended for Alleged Unsuitable Investment Recommendations

Maxim Tulupnikov (CRD #: 6188857), a broker registered with David Lerner Associates, has been suspended by FINRA. This is according to his BrokerCheck record, accessed on July 6, 2025. Investors may have also worked with him through Spirit of America Management Corporation. Keep reading for more information about his alleged conduct as a broker.

FINRA Suspension

On May 20, 2025, Maxim Tulupnikoff consented to the entry of findings that he allegedly recommended that two customers invest in two limited partnerships without a reasonable basis to believe these investments were suitable for them.

According to a Letter of Acceptance, Waiver & Consent (AWC), Maxim Tulupnikoff allegedly recommended that a married couple invest in two limited partnerships formed in order to acquire and develop hydrocarbon-producing properties.

These limited partnerships allegedly had objectives including making distributions to investors and potentially engaging in a liquidity event five-to-seven years after the termination of their offerings. These distributions and possible liquidity events would depend on the performance of the LPs’ properties.

Their prospectuses allegedly described investments in these partnerships as being illiquid, high-risk, speculative, and long-term in scope.

Customers A and B were allegedly saving for retirement and had a moderately conservative risk tolerance. Between October 2015 and March 2019, Maxim Tulupnikoff allegedly recommended nine purchases of the limited partnerships totaling $147,946 in their joint account and IRAs.

The AWC concluded that these allegations constituted violations of FINRA Rules 2111 and 2010.

FINRA Rule 2111

FINRA Rule 2111 defines suitable investments as securities that fit an investor’s profile. Investors’ profiles include information concerning their financial goals, other investments, and personal information like their age.

Some common violations of this rule include:

• Recommendations of high-risk investments, which are more likely to lose money.

• Recommendations of illiquid securities that, since they are meant to be held long-term, can incur high fees for investors who attempt to cash out early.

• A broker executing an excessive number of trades violates the requirement for quantitative suitability.

These requirements also apply to the overall investment strategy a broker recommends or enacts. For instance, an investment strategy that overconcentrates the investor’s account in one stock or sector is likely unsuitable.

Investors who rely on brokers for recommendations may be able to recover their losses through FINRA arbitration.

FINRA Rule 2010

FINRA Rule 2010 holds brokers to high standards of commercial honor and just and equitable principles of trade.

Sanctions

Maxim Tulupnikoff consented to the following sanctions:

• Two-month suspension from associating with FINRA members

• $5,000 fine

You can read the AWC here.

FINRA also accepted another AWC from David Lerner Associates in connection with these investors’ allegations. This AWC allegedly ordered restitution of $7,949.16 and $927.60 to these clients.

Background Information

Maxim Tulupnikov has passed the following exams:

• Series 65 Uniform Investment Adviser Law Examination

• Series 63 Uniform Securities Agent State Law Examination

• SIE – Securities Industry Essentials Examination

• Series 7 General Securities Representative Examination

He is a registered broker in 13 states and is a registered investment adviser in Connecticut.

Kurta Law Can Help

If you worked with Maxim Tulupnikov and you have concerns about your investments, please contact us today at 877-600-0098 or info@kurtalawfirm.com for a free consultation.

For over 20 years, Kurta Law has advocated on behalf of investors who want to recover their investment losses from brokers and brokerage firms. Kurta Law is a nationally recognized law firm and exclusively represents investors against brokers and brokerage firms on a contingency basis. This means that the firm only earns a fee if our securities attorneys recover money on your behalf.