Former Hilltop Securities Broker Dennis Ayre Barred from Securities Industry

National Investment Fraud Lawyers KlaymanToskes is investigating (“Hilltop Securities Dennis Ayre Investigation”) former California-based securities broker Dennis Phillip Ayre. He was recently barred from the securities industry for refusing to appear for on-the record testimony to the Financial Industry Regulatory Authority (“FINRA”) relating to customer suitability matters.

Dennis Phillip Ayre’s Registration History

Ayre was most recently registered with Hilltop Securities from August 2019 to July 2020, per his FINRA BrokerCheck. Before joining Hilltop Securities, Ayre was registered with Integrated Advisors Network as an investment advisor representative from April 2017 to August 2019, and was registered with Oppenheimer & Co., Inc. in Los Angeles, CA from March 2014 to May 2017.

FINRA Bars Dennis Ayre

Per a January 2022 Financial Industry Regulatory Authority (“FINRA”) Letter of Acceptance, Waiver & Consent, Ayre consented to a bar from associating with any FINRA member in all capacities for refusing to appear to provide on-the-record testimony relating to the regulator’s investigation into the suitability of certain investment recommendations Ayre made to customers while he was registered with FINRA.

Brokerage firms and its financial advisors must only recommend suitable investments to their customers. Unsuitable investment advice is an investment recommendation that is not consistent with an investor’s investment objectives, risk tolerance and investment time horizon. Each customer should have its own specific determination of suitability based on its particular circumstances.

FINRA established a “suitability” rule which requires brokerage firms and its financial advisors to have a “reasonable basis” for recommending investments or investment strategies, as suitable based on a customer’s investment profile. The rule requires “reasonable diligence” to gather all necessary information to formulate a basis for recommendations based on the following customer investment profile information:

  • age;
  • other investments;
  • employment status;
  • tax status;
  • investment objectives;
  • financial situation and needs;
  • investment experience;
  • investment time horizon;
  • liquidity needs;
  • risk tolerance, and
  • any other information disclosed by customer in connection with recommendation.

What is a FINRA AWC?

Phillip Dennis Ayre consented to sanctions, as disclosed in a FINRA Letter of Acceptance, Waiver and Consent (“AWC”). But what is an AWC?

If FINRA’s Department of Enforcement has reason to believe a violation has occurred and the member or associated person does not dispute the violation, the Department of Enforcement may prepare and request that the member or associated person execute a letter accepting a finding of violation, consenting to the imposition of sanctions, and agreeing to waive such member’s or associated person’s right to a hearing before a Hearing Panel or, if applicable, an Extended Hearing Panel, and any right of appeal to the National Adjudicatory Council, the SEC, and the courts, or to otherwise challenge the validity of the letter, if the letter is accepted.

The letter shall describe the act or practice engaged in or omitted, the rule, regulation, or statutory provision violated, and the sanction or sanctions to be imposed. Unless the letter states otherwise, the effective date of any sanction(s) imposed will be a date to be determined by FINRA staff.

Recover Hilltop Securities Dennis Ayre Investment Losses

Former customers of Dennis Phillip Ayre with losses in excess of $250,000, and those who have information relating to the manner in which he handled customer accounts, are encouraged to contact Lawrence L. Klayman, Esq., at 888-997-9956, and download our Special Investor Report.

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KT is a leading national securities law firm which practices exclusively in the field of securities arbitration on behalf of retail and institutional investors throughout the world in large and complex securities matters. KT has recovered more than $228 million for investors in FINRA arbitrations. KT has office locations in California, Florida, New York, and Puerto Rico.

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