Michael Clifford Graham (CRD #3263494) Has Customer Dispute, Employment Separation, and Judgment/Lien Disclosures on FINRA BrokerCheck
Michael Clifford Graham (CRD #3263494) has been the subject of disclosure events, which have been reported on FINRA BrokerCheck. According to Michael Graham’s FINRA BrokerCheck Report, these disclosures include customer disputes, an employment separation, and financial judgments/liens.
BrokerCheck link: BrokerCheck
BrokerCheck report: BrokerCheck Report (PDF)
Investor Disputes / Customer Complaints
Michael Graham’s FINRA BrokerCheck Report reflects five customer dispute disclosures.
On November 19, 2025, a client alleged that Michael Graham fraudulently offered a short-term loan note with a guaranteed 150% return that was not affiliated with LPL Financial LLC. The claim alleges damages of $375,000 and remains pending.
On January 15, 2025, a customer alleged that Michael Graham recommended a private securities investment that was unsuitable for the customer’s investment objectives and risk tolerance, and that he engaged in securities transactions away from the firm. The customer alleged $276,200 in damages, the matter was filed as a FINRA arbitration (Docket No. 25-00075), and it later settled for $175,000.
BrokerCheck reflects three additional customer dispute disclosures involving Michael Graham.
Employment Separation After Allegations
Michael Graham’s FINRA BrokerCheck Report reflects one employment separation disclosure.
On June 6, 2025, LPL Financial LLC discharged Michael Graham after allegations that he failed to disclose and obtain prior approval for participating in a prohibited outside business activity, and that he participated in and directed clients to private investments.
Judgment / Lien
Michael Graham’s FINRA BrokerCheck Report reflects four judgment/lien disclosures.
On July 25, 2023, a tax lien in the amount of $26,944.29 was filed by the State of New Mexico and remains outstanding (Docket No. L1413587568).
On July 17, 2023, a tax lien in the amount of $563,677.48 was filed by the Internal Revenue Service and remains outstanding (Docket No. 476849623).
BrokerCheck reflects two additional judgment/lien disclosures involving Michael Graham.
Rule summary #1: FINRA Rule 3270 (Outside Business Activities of Registered Persons)
FINRA Rule 3270 (Outside Business Activities of Registered Persons) requires registered persons to provide prior written notice to their member firm before engaging in outside business activities for compensation or with a reasonable expectation of compensation. The rule helps firms evaluate conflicts of interest and supervise activities that could impact investors.
Rule summary #2: FINRA Rule 3280 (Private Securities Transactions of an Associated Person)
FINRA Rule 3280 (Private Securities Transactions of an Associated Person) requires associated persons to provide written notice to their firm before participating in private securities transactions. Depending on the circumstances, a firm may be required to approve the transaction and supervise the activity, which is designed to protect investors from unapproved or unsupervised recommendations.
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, Michael Graham:
- Is not currently registered.
- Was most recently registered with LPL Financial LLC (04/2019–06/2025) and previously with Principal Securities, Inc. and Securian Financial Services, Inc.
- Has passed the Series 51, Series 24, Securities Industry Essentials (SIE), Series 7, Series 6, Series 65, and Series 63 exams.
Kurta Law Can Help
If you have worked with Michael Graham and you have concerns about his activity, Kurta Law may be able to help you evaluate potential recovery options. You may be entitled to pursue a claim through FINRA arbitration, depending on the facts of your situation and the investments involved. Contact Kurta Law at 877-600-0098 or info@kurtalawfirm.com for a free consultation.
Helpful resources: Selling Away | Stockbroker Fraud
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