Ray Lent Censured by SEC for Second Time

Ray Lent (CRD #: 817645), a broker registered with Arete Wealth Management, has been censured by the SEC, according to his BrokerCheck record, accessed on May 18, 2025. Investors may have also worked with him through The Putney Financial Group. If you want to know more about his alleged conduct as a broker, read on.

SEC Regulatory Action

On May 20, 2024, the Securities and Exchange Commission filed a regulatory action against Ray Lent (dba The Putney Financial Group), alleging that he violated Section 206(2) of the Investment Advisers Act of 1940 in relation to his alleged receipt of third-party compensation via revenue sharing agreements and sales commissions from his clients without providing full and fair disclosure of his conflicts of interest.

The SEC further alleged that he violated Section 206(4) of the Investment Advisers Act by failing to implement written policies and procedures designed to prevent violations of the Investment Advisers Act.

Investment Advisers Act of 1940

Section 206 of the Investment Advisers Act prohibits the use of deceptive, manipulative, and otherwise fraudulent schemes and practices by investment advisers.

Sanctions

Ray Lent was censured by the SEC and ordered to cease and desist from violations of Section 206(2) and 206(4) of the Investment Advisers Act. He was also subject to the following sanctions:

• $175,000 fine
• Disgorgement of $890,366.18
• Undisclosed undertakings

Investor Disputes

On February 28, 2025, an investor alleged that Ray Lent sold them an unsuitable investment. This dispute is currently pending.

In a dispute filed on April 18, 2023, an investor alleged that Ray Lent engaged in negligence and misrepresentation, and breached his contract. The client received a settlement of $145,000.

On February 27, 2023, an investor named Ray Lent in a dispute alleging failure to conduct reasonable due diligence and an unsuitable investment recommendation. This dispute was settled for $114,349.35.

A dispute filed on February 27, 2023, alleged that Ray Lent failed to conduct reasonable due diligence, made misrepresentations, and failed to fully disclose information to the client. This dispute was settled for $228,843.38.

FINRA Rule 2111 and Regulation Best Interest

FINRA Rule 2111 requires brokers to take investors’ profiles into account when recommending investments. These profiles describe an investor’s age, risk tolerance, and financial goals.

Regulation Best Interest (Reg-BI) is an SEC regulation that requires brokerage firms to put their clients’ best interests first. For example, firms must conduct reasonable due diligence when researching investments to ensure their recommendations are suitable for the investor.

FINRA Rule 2020

FINRA Rule 2020 prohibits the use of manipulative, deceptive, or otherwise fraudulent methods to influence investors’ decisions. This includes the misrepresentation or omission of information related to investments.

FINRA Rule 2010

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

SEC Censure

On March 11, 2019, the Securities and Exchange Commission executed cease-and-desist proceedings against Ray Lent (d/b/a The Putney Financial Group) for allegedly breaching his fiduciary duty as an investment adviser and providing inadequate disclosures to clients with regard to The Putney Financial Group’s mutual fund share class selection practices and 12b-1 fees.

According to the SEC, between January 1, 2014, and June 7, 2018, Ray Lent allegedly purchased, recommended, or held mutual fund share classes for advisory clients that charged 12b-1 fees despite these clients being eligible for lower-cost share classes of the same funds.

The Putney Financial Group allegedly failed to disclose in its Form ADV its conflicts of interest related to its receipt of 12b-1 fees and/or its selection of mutual fund share classes that paid the firm these fees.

Ray Lent allegedly self-reported these violations to the SEC as part of the Share Class Selection Disclosure Initiative, wherein the SEC encouraged investment advisors to report their violations of Rule 12b-1 of the Investment Company Act of 1940 for a favorable settlement.

The SEC alleged that Ray Lent willfully violated Sections 206(2) and 207 of the Investment Advisers Act of 1940.

Investment Advisers Act of 1940

Section 207 prohibits investment advisers and firms from making untrue statements or willful omissions in registration applications or reports filed with the SEC.

Sanctions

Ray Lent consented to the following sanctions:

• Censure
• Disgorgement of $39,546.51
• Other monetary penalty of $3,488.32
• Unspecified undertakings

He and The Putney Financial Group were also ordered to cease and desist from violations of Sections 206(2) and 207 of the Investment Advisers Act of 1940.

Background Information

Ray Lent has passed the following exams:

• General Securities Principal Examination – Series 24
• Securities Industry Essentials Examination – SIE
• General Securities Representative Examination – Series 7
• Registered Representative Examination – Series 1
• Uniform Investment Adviser Law Examination – Series 65
• Uniform Securities Agent State Law Examination – Series 63

Ray Lent is a registered broker in six states. He is also a registered investment adviser in California.

He has also worked for the following firms:

• Portsmouth Financial Services (CRD#:13980)
• McClurg Capital Corporation (CRD#:16798)
• Park Avenue Securities (CRD#:46173)
• Guardian Investor Services (CRD#:6635)
• Centaurus Financial (CRD#:30833)
• Mony Securities Corporation (CRD#:4386)
• The Mutual Life Insurance Company of New York (CRD#:2873)

Kurta Law Can Help

If you worked with Ray Lent 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.