The Financial Industry Regulatory Authority (“FINRA”) has barred Dee Dee Brooks, of Sarasota, Florida, based on findings that, while acting as an agent of Signator Investors, Inc., Brooks engaged in private securities transactions without any notice to or approval from her firm.
According to FINRA’s findings, From July 2016 to December 2017, Brooks solicited investors to purchase more than $1.77 million in securities in the Woodbridge Group of Companies, LLC, a purported real estate investment fund, and Future Income Payments, LLC, a company claiming to be a “structured cash flow investment company.”
FINRA found that Brooks, through a company she worked with as an outside business, convinced nine investors, most of whom were Signator customers, to invest $906,497 in Woodbridge promissory notes. Likewise, Brooks sold $866,895 in FIP purchase agreements to seven investors, six of whom were Signator customers. FINRA found that Brooks did not give notice to Signator of these transactions nor obtain Signator’s approval.
In December 2017, the Woodbridge filed for Chapter 11 bankruptcy. In December 2018, the US District Court for the Southern District of Florida issued final judgments against Woodbridge and its former owner, Robert H. Shapiro. The judgments required Woodbridge and Shapiro to disgorge ill-gotten gains and pay a civil penalty.
In April 2018, FIP cased business, owing nearly $300 million in unpaid investor payments. In March 2019, the United States handed down indictments charging FIP and its former owner, Scott A Kohn, with conspiracy to engage in mail and wire fraud related to FIP’s operations.
FINRA found that Brooks violated FINRA Rules 3280 and 2010 by not gaining approval or providing notice to her firm regarding any of these investments to the two funds solicited to its own customers. Consequently, Brooks was permanently barred from association with any FINRA member in all capacities.
According to Brooks’ FINRA BrokerCheck report, Signator allowed Brooks to resign voluntarily in June 2018 while the firm was investigating Brooks’ involvement in the sale of unregistered securities. Brooks was also the subject of a May 2018 customer complaint alleging a $118,000 loss in the Woodbridge Mortgage Investment Fund; that claim was settled for $75,000.