Ray Davis & Behavioral Recognition Systems, Inc. (BRS) — Alleged Fraudulent Scheme Involving Material Misrepresentations

Ray C. Davis and Behavioral Recognition Systems, Inc., or BRS, Allegedly Solicited over $28 Million from Investors in Seven Equity Offerings between January 2013 and July 2015

Ray Davis and Behavioral Recognition Systems, Inc., or BRS, allegedly solicited over $28 million from investors in seven equity offerings between January 2013 and July 2015, according to an SEC Complaint currently under review by attorneys Alan Rosca and James Booker.

Peiffer Rosca Wolf securities practice lawyers are investigating Behavioral Recognition Systems, Inc.’s alleged fraudulent scheme involving material misrepresentations.

Investors who believe they may have lost money in activity related to Behavioral Recognition Systems, Inc.’s alleged fraudulent scheme involving material misrepresentations are encouraged to contact attorneys Alan Rosca or James Booker with any useful information or for a free, no obligation discussion about their options.

BRS (now known as Giant Gray, Inc.) allegedly made material misrepresentations and misleading statements to investors regarding BRS’s  intended use of investor proceeds, executive compensation, related party transactions, and operating expenses, according to the aforementioned Complaint.

Davis also allegedly took part in and largely helped BRS’s material misstatements to investors, and was the highest-ranking executive at BRS and the executive in charge of fund raising, the Complaint notes.

Ray Davis Allegedly Siphoned $7.8 Million from Investors for His Own Person Use and Benefit

Ray Davis was also allegedly responsible for the company’s offering documents, which contained multiple false and misleading statements, and he also purportedly took part in drafting and approving said documents, authorized their distribution to prospective investors, and personally used them to raise funds for BRS from prospective investors, according to the aforementioned SEC Complaint under review by attorneys Alan Rosca and James Booker.

BRS allegedly claimed in the offering documents that investor funds would be used for “growth,” “mezzanine funding,” “working capital,” and “general corporate purposes” to build BRS, but Davis instead allegedly siphoned approximately $7.8 million for his own use and benefit, the Complaint notes.

For example, in contrast to the statements in the offering documents, Davis allegedly made $5.2 million in transfers to Davis’s and his wife’s joint bank account, made purchases from an art gallery in Boca Raton, Florida, and made payments to a well- known auction house, the Complaint states.

Securities Lawyers Investigating

The Peiffer Rosca Wolf securities lawyers often represent investors who lose money as a result of investment-related fraud or misconduct and are currently investigating Behavioral Recognition Systems, Inc.’s alleged fraudulent scheme involving material misrepresentations. They take most cases of this type on a contingency fee basis and advance the case costs, and only get paid for their fees and costs out of money they recover for their clients.

Investors who believe they lost money as a result of Behavioral Recognition Systems, Inc.’s alleged fraudulent scheme involving material misrepresentations may contact the securities lawyers at Peiffer Rosca Wolf, Alan Rosca or James Booker, for a free no-obligation evaluation of their recovery options, at 888-998-0520 or via e-mail at arosca@prwlegal.com or jbooker@prwlegal.com.

 

 

 

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Craig Lewis — Alleged Undisclosed Business Activity

Craig Edward Lewis May Have Allegedly Engaged in Undisclosed Outside Business Activity by Making Sales of Equity Indexed Annuities through a Third-party Life Insurance Firm to Many Customers of His Member Firm

Craig Lewis, a former Valic broker, allegedly engaged in undisclosed outside business activity by making sales of equity indexed annuities via a third-party life insurance company to several customers of his employer member firm, according to a recent Letter of Acceptance, Waiver, and Consent (AWC) presently being reviewed by attorneys Alan Rosca and James Booker.

Investors who believe they may have lost money in activity related to Craig Lewis’s alleged undisclosed business activity are encouraged to contact attorneys Alan Rosca or James Booker with any useful information or for a free, no obligation discussion about their options.

The Peiffer Rosca Wolf securities lawyers are currently investigating Craig Lewis’s alleged undisclosed business activity.

Lewis also allegedly directed trading activity in a customer’s securities account held away from his member firm without disclosing to that member firm that he was a registered representative and without disclosing his activities to his member firm, the AWC notes.

What is more, Craig Lewis allegedly traded away in an undisclosed personal securities account held at another FINRA member firm without disclosing to that member firm that he was a registered representative, the AWC states.

Craig Lewis Barred by FINRA

Craig Edward Lewis, based on the aforementioned behavior, allegedly violated FINRA Rules and hence has been barred by FINRA, according to the aforementioned AWC presently under review by attorneys Alan Rosca and James Booker.

In March of 2016, Valic allegedly terminated its affiliation with Lewis and he has not been employed in the industry since, the AWC states.

Lewis started his securities career in 1981 at A.G. Edwards and reportedly worked at eight securities firms before joining Valic in 2012, the AWC notes.

Lewis is currently not associated with a FINRA member firm, has no prior disciplinary history, and although Lewis is not currently associated with a FINRA member firm or registered with FINRA, he is subject to FINRA’s jurisdiction pursuant to FINRA’s By-Laws, the AWC notes.

Finally one should also note that, according to the AWC, Craig Edward Lewis neither admitted nor denied the FINRA findings.

Securities Lawyers Investigating

The Peiffer Rosca Wolf securities lawyers often represent investors who lose money as a result of investment-related fraud or misconduct and are currently investigating Craig Lewis’s alleged undisclosed business activity. They take most cases of this type on a contingency fee basis and advance the case costs, and only get paid for their fees and costs out of money they recover for their clients.

Investors who believe they lost money as a result of Craig Lewis’s alleged undisclosed business activity may contact the securities lawyers at Peiffer Rosca Wolf, Alan Rosca or James Booker, for a free no-obligation evaluation of their recovery options, at 888-998-0520 or via e-mail at arosca@prwlegal.com or jbooker@prwlegal.com.

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David Lee Reynolds — Alleged Misappropriation of Customer Funds

David Lee Reynolds Allegedly Misappropriated Customer Funds as Reported on an Amended Form U5 by his Former Member Firm

David Lee Reynolds allegedly misappropriated customer funds reported on an amended Form U5 by his former member firm, according to a recent Letter of Acceptance, Waiver, and Consent (AWC) presently being reviewed by attorneys Alan Rosca and James Booker.

Investors who believe they may have lost money in activity related to David Lee Reynolds’ alleged misappropriation of customer funds are encouraged to contact attorneys Alan Rosca or James Booker with any useful information or for a free, no obligation discussion about their options.

The Peiffer Rosca Wolf securities lawyers are currently investigating David Lee Reynolds’ alleged misappropriation of customer funds.

Reynolds reportedly entered the securities industry when he became associated with a FINRA member firm and became registered with FINRA as a General Securities Representative, or GSR, in 2003, and became associated with Principal Securities, Inc. as a GSR in May 2008, where he remained until December 2015, the AWC notes.

Reynolds then allegedly became associated with another FINRA member firm as a GSR, where he remained until October 2017, the AWC states.

David Lee Reynolds Allegedly Refused to Cooperate with a FINRA Request for Documents and Information

David Reynolds, on October 6, 2017, allegedly received a request from FINRA staff to comply with a FINRA request for documents and information issued pursuant to FINRA Rules, according to the aforementioned AWC presently under review by attorneys Alan Rosca and James Booker.

Reynolds, as stated in his counsel’s e-mail to FINRA staff on November 2, 2017, allegedly acknowledged that he received FINRA’s request and that he would not produce the documents and information requested.

Reynolds, by refusing to produce documents and information as requested pursuant to FINRA Rules, allegedly violated FINRA Rules  and therefore was banned by FINRA, the AWC notes.

FINRA Rules state that “[n]o member or person shall fail to provide information or testimony or to permit an inspection and copying of books, records, or accounts pursuant to this Rule,” the AWC reports.

Finally one should also note that, according to the AWC, David Lee Reynolds neither admitted nor denied the FINRA findings.

Securities Lawyers Investigating

The Peiffer Rosca Wolf securities lawyers often represent investors who lose money as a result of investment-related fraud or misconduct and are currently investigating David Lee Reynolds’ alleged misappropriation of customer funds. They take most cases of this type on a contingency fee basis and advance the case costs, and only get paid for their fees and costs out of money they recover for their clients.

Investors who believe they lost money as a result of David Lee Reynolds’ alleged misappropriation of customer funds may contact the securities lawyers at Peiffer Rosca Wolf, Alan Rosca or James Booker, for a free no-obligation evaluation of their recovery options, at 888-998-0520 or via e-mail at arosca@prwlegal.com or jbooker@prwlegal.com.

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Paul Smith — Investment Advisory Fraud

Paul W. Smith, an Ex-broker, Allegedly Operated a Decades Long Investment Advisory Fraud Raising Approximately $2.35 Million from Roughly 30 Investors; Smith Allegedly Claimed He would Invest in Securities but then Purportedly Used the Money for Personal Use or to Repay other Investors

Ex-broker Paul Smith, from 1991 to 2016, allegedly raised approximately $2.35 million from about 30 investors as part of a decades long investment advisory fraud, according to an SEC Complaint filed in federal court in Philadelphia under review by attorneys Alan Rosca and James Booker.

Peiffer Rosca Wolf securities practice lawyers are investigating Paul Smith’s alleged investment advisory fraud scheme.

Investors who believe they may have lost money in activity related to Paul Smith’s alleged investment advisory fraud scheme are encouraged to contact attorneys Alan Rosca or James Booker with any useful information or for a free, no obligation discussion about their options.

Paul Smith allegedly made claims to investors that he would put their money into publicly traded securities via The Haverford Group, an outside partnership that he purportedly made and did not disclose to his broker-dealer employers, the Complaint states.

What is more, Smith allegedly executed very few securities investments and instead predominately used investor cash for his own personal use and to repay other investors, the Complaint notes.

Smith started his securities career in 1982 at Prudential-Bache Securities and worked at five firms before joining Bolton, where he reportedly worked from 2007 to 2017, according to his FINRA BrokerCheck Report. Furthermore, Smith worked at Philadelphia Brokerage Corp. from 2002 to 2007, Tucker Anthony from 2000 to 2002, and at Janney Montgomery Scott from 1990 to 2000, FINRA notes.

Smith, age 63, is resident of Wayne,Pennsylvania, and since 1991, he has allegedly acted as Haverford’s investment adviser, but, in contravention of Broker-Dealer-1 ‘s policies and procedures, Smith allegedly did not inform Broker-Dealer-I about Haverford, or his role as its adviser, the Complaint notes.

Smith allegedly created “The Haverford Group Subscription Agreement & Disclosure Document” which he purportedly advertised as being ”formed to make investments” and “provide [investors] with a high level of current income and capital appreciation as is consistent with the preservation ofcapital and the maintenance of liquidity,” the Complaint notes.

Smith Allegedly Convinced Trusting and Vulnerable Customers to Invest Money in Haverford, Including Many Elderly and Retired Persons; Smithe Barred in June by FINRA in Alleged Connection with Activities Charged in the SEC Case

Paul Smith was barred in June by FINRA in connection with the aforementioned alleged activities charged in the SEC case, according to the aforementioned Complaint being reviewed by attorneys Alan Rosca and James Booker.

Smith purportedly convinced some of his most trusting and vulnerable brokerage customers, many of whom were retired or elderly, to invest their money in Haverford while Smith allegedly knew that the investment was not legitimate, that he would purportedly not use all of their money to purchase securities on their behalf as promised, and purportedly would instead would use most of their money to repay other investors and for his own personal use, according to the SEC Complaint.

Furthermore, the SEC further alleges that Smith allegedly worked hard to hide his scheme and purportedly fabricated phony account statements that showed fictitious account balances and gains, the Complaint states.

Smith also allegedly kept his and Haverford’s activities and accounts hidden from his employers, and used funds from investors to repay others in order to quell suspicion, the Complaint states.

Matters in the case came to a head when Smith’s alleged scheme purportedly collapsed in October 2016 when an investor Smith allegedly failed to repay complained to the police, the Complaint notes.

What is more, Smith allegedly has 11 customer disputes listed on his broker report, according to his FINRA BrokerCheck Report.

Smith, by “knowingly or recklessly” engaging in the alleged conduct described in the SEC Complaint, allegedly violated Sections of the Securities Act, the Complaint states.

The SEC is seeking to enjoin Smith from engaging in the transactions, acts, practices, and courses of business alleged in the Complaint, disgorgement of allegedly ill-gotten gains from the purported unlawful conduct mentioned in the Complaint, together with prejudgment interest, and other relief as the Court may deem appropriate, the Complaint reports.

Securities Lawyers Investigating

The Peiffer Rosca Wolf securities lawyers often represent investors who lose money as a result of investment-related fraud or misconduct and are currently investigating Paul Smith’s alleged investment advisory fraud scheme. They take most cases of this type on a contingency fee basis and advance the case costs, and only get paid for their fees and costs out of money they recover for their clients.

Investors who believe they lost money as a result of Paul Smith’s alleged investment advisory fraud scheme may contact the securities lawyers at Peiffer Rosca Wolf, Alan Rosca or James Booker, for a free no-obligation evaluation of their recovery options, at 888-998-0520 or via e-mail at arosca@prwlegal.com or jbooker@prwlegal.com.

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