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Richard Hogan Suspended by FINRA for Alleged Selling Away

Richard Hogan (CRD #: 1754577), a broker formerly registered with Merrill Lynch, Pierce, Fenner & Smith, has been suspended by FINRA, according to his BrokerCheck record, accessed on September 30, 2022. Keep reading if you have questions about his conduct as a broker.

Suspension by FINRA

On July 26, 2022, Richard Hogan consented to the entry of findings that he allegedly participated in private securities transactions between October 2017 and August 2018 without providing prior written notice to his firm, Merrill Lynch, Pierce, Fenner & Smith.

A Letter of Acceptance, Waiver & Consent (AWC) alleges that, during this time, Merrill Lynch’s written supervisory procedures (WSPs) outlined the following policies:

  • Brokers were prohibited from soliciting clients to invest in private investment opportunities not offered by the firm.
  • Brokers could only purchase investments away from the firm if their clients were not also investing in the same entity.
  • Brokers must obtain firm approval before purchasing investments away from the firm through the firm’s Associate Investment Monitoring (AIM) system.

According to the AWC, Richard Hogan allegedly solicited clients to participate in five private securities transactions in equity funds based in Hong Kong and Vietnam and directed his assistants to process the documentation for these transactions. Clients allegedly invested a total of $630,000 in these equity funds.

Richard Hogan allegedly failed to disclose these transactions to his firm, and in December 2018, disclosed in the AIM system that though he had personally invested in the Hong Kong equity fund, he had not co-invested or solicited clients for the investment.

The AWC concludes that these allegations constituted violations of FINRA Rules 3280 and 2010.

FINRA Rule 3280 and 2010

FINRA Rule 3280 requires brokers to provide notice to their firm before engaging in private securities transactions, including those involving their clients and products offered by other firms.

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


Richard Hogan consented to the following sanctions:

  • $10,000 fine
  • 12-month suspension

His suspension began on August 1, 2022, and will end on July 31, 2023.

You can read the full AWC here.

Termination from Merrill Lynch, Pierce, Fenner & Smith

On June 4, 2020, Richard Hogan was fired from Merrill Lynch, Pierce, Fenner & Smith after he allegedly introduced clients to third parties so they could make investments not offered or sponsored by the firm, failed to disclose or receive approval from the firm for his co-investment with these clients, failed to sufficiently safeguard his personal log-on credentials, and failed to complete mandatory firm training.

Background Information

Richard Hogan has passed the following exams:

  • Series 66 – Uniform Combined State Law Examination
  • Series 63 – Uniform Securities Agent State Law Examination
  • SIE – Securities Industry Essentials Examination
  • Series 31 – Futures Managed Funds Examination
  • Series 7 – General Securities Representative Examination
  • Series 3 – National Commodity Futures Examination
  • Series 24 – General Securities Principal Examination

In the past, he worked for the following firms:

  • Merrill Lynch, Pierce, Fenner & Smith (CRD#:7691)
  • myCFO Securities (CRD#:111657)
  • Goldman, Sachs & Company (CRD#:361)
  • Salomon Brothers (CRD#:740)

Kurta Law Can Help

If you worked with Richard Hogan 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. 

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