Jerry Perlman (CRD # 360372, Registered Representative, Boca Raton, Florida) submitted a Letter of Acceptance, Waiver and Consent in which he was barred from association with any FINRA member in any capacity. Without admitting or denying the findings, Perlman consented to the described sanction and to the entry of findings that, while exercising control over the trust account for the benefit of an elderly customer, and while acting with the requisite scienter, he excessively traded the account in a manner that was inconsistent with the customer’s investment objectives, financial situation and needs. The findings stated that Perlman recommended transactions to the customer without having reasonable grounds for believing that such transactions were suitable in light of the frequency of such transactions, the level of margin used in the account, and the customer’s financial situation, investment objectives and needs. The findings also stated that Perlman’s trading, for the life of the account, resulted in losses of approximately $551,000 and generated gross commissions of approximately $118,000 and margin interest of approximately $9,300.

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