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FINRA Suspends Pat Perugino for Alleged Unauthorized Trading

Pat Perugino (CRD #: 6363411), a broker registered with Craft Capital Management, was recently suspended by FINRA, according to his BrokerCheck record, accessed on February 2, 2023. If you want to know more about his alleged conduct as a broker, read on.

FINRA Suspension

On December 5, 2022, Pat Perugino consented to the entry of findings that he allegedly exercised his trading discretion in four client accounts, executing trades without prior written authorization from the clients or the authorization of David Lerner Associates, Spartan Capital Securities, or Craft Capital Management.

According to a Letter of Acceptance, Waiver & Consent (AWC), Pat Perugino allegedly executed 183 unauthorized trades between December 2016 and August 2021. At the time, David Lerner Associates and Spartan Capital Securities’ Written Supervisory Procedures (WSPs) prohibited brokers from engaging in discretionary trading in client accounts.

Craft Capital Management’s WSPs allegedly permitted discretionary trading, but the AWC alleged that Pat Perugino did not obtain written authorization from the clients nor did he seek approval from his firm.

Further, Pat Perugino allegedly incorrectly claimed in two annual attestations submitted to Craft Capital Management that he did not handle any discretionary accounts.

The AWC concluded that these allegations constituted violations of NASD Rule 2510(b) and FINRA Rules 3260(b) and 2010.

FINRA Rule 3260

Unauthorized trading violates FINRA Rule 3260, which limits brokers to exercising their trading discretion in pre-approved discretionary accounts.

FINRA Rule 2010

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


Pat Perugino consented to the following sanctions:

  • $5,000 fine
  • 1-month suspension

His suspension ran from January 3 to February 2, 2023.

You can read the full AWC here.

Termination from David Lerner Associates

On November 16, 2017, Pat Perugino was fired from David Lerner Associates following allegations that he engaged in unauthorized trading.

Background Information

Pat Perugino has passed the following exams:

  • Series 63 – Uniform Securities Agent State Law Examination
  • SIE – Securities Industry Essentials Examination
  • Series 7 – General Securities Representative Examination

Pat Perugino is a registered broker in seven states.

He has also worked for the following firms:

  • Spartan Capital Securities (CRD#:146251)
  • Allied Millennial Partners (CRD#:16569)
  • David Lerner Associates (CRD#:5397)
  • AXA Advisors (CRD#:6627)
  • First Allied Securities (CRD#:32444)

Kurta Law Can Help

If you worked with Pat Perugino and you have concerns about your investments, please contact us today at 877-600-0098 or 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.