JUSTIN PAGEL Suspended by FINRA – Goodman & Nekvasil, P.A.

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Without admitting or denying the findings, Pagel consented to the sanction and to the entry of findings that he made recommendations to three customers that that were not suitable, and he willfully violated Rule 15l-1(a)(1) of the Exchange Act (Reg BI) by making recommendations to another customer that was not in his best interest.

The findings stated that when opening their accounts with Pagel, each of the three customers instructed him to invest the money conservatively and informed him that they planned to use the money for anticipated upcoming expenses, such as a home down payment or a child’s college tuition.

At Pagel’s recommendation, the three customers invested all, or a significant portion of, their assets at Pagel’s member firm in low-priced stocks or other speculative securities. The trading activity in these accounts was inconsistent with the customers’ investment profiles and resulted in losses and customer complaints from all three customers.

In connection with two of the complaints, Pagel and the firm made payments totaling $26,000. In addition, the other customer informed Pagel that he wanted to make only safe investments. However, Pagel recommended that the other customer purchase positions in low-priced stocks and other speculative securities inconsistent with his investment profile.

The findings also stated that Pagel exercised discretion when effecting trades in customer accounts without obtaining written authorization from the customers and from his firm to treat the accounts as discretionary. The findings also included that Pagel mismarked solicited trades as unsolicited in customer accounts, including the accounts in which he exercised discretion without authorization.

Pagel consented to a ten-month suspension.