Bulletin # 3128 - Week Ending February 2, 2024

This bulletin constitutes the only official notification you will receive from this office concerning any of the following applications.  Any observations you may have are solicited.  Any comments should be in writing to Jorge L. Perez, Banking Commissioner, Department of Banking, 260 Constitution Plaza, Hartford, CT 06103-1800.  Written comments will be considered only if they are received within ten business days from the date of this bulletin.

SECURITIES AND BUSINESS INVESTMENTS DIVISION ACTIVITY 

Andrew M. Komarow (CRD No. 5838564)

On January 31, 2024, the Banking Commissioner entered a Consent Order (No. CO-24- 20233-S) with respect to Andrew M. Komarow of 75 Juniper Drive, Avon, Connecticut 06001. Respondent had been registered as a broker-dealer agent and investment adviser agent during the preceding years. The Consent Order noted that Respondent had been discharged from prior firms for attempting to put through ACH transactions when there were insufficient funds on hand; that FINRA had issued a bar against Komarow; and that, on December 8, 2023, the Securities and Exchange Commission had filed suit against Komarow alleging that he engaged in improper freeriding schemes. The Consent Order alleged that Respondent violated Section 36b-4 of the Connecticut Uniform Securities Act.

The Consent Order directed Komarow to cease and desist from regulatory violations; denied him investment adviser agent registration; and barred him indefinitely from transacting business as a broker-dealer, agent, investment adviser or investment adviser agent in the state of Connecticut. Based on the contents of the financial affidavit submitted by the Respondent which showed that he did not have the ability to pay the fine that otherwise would have been imposed against him pursuant to Section 36b-27 of the Act, the Commissioner temporarily stayed such fine for three years from the date of the Consent Order. After three years, the stay would no longer be in force and effect if the Respondent remained unable to pay the fine, and the fine would be waived.

Raymond James & Associates, Inc. (CRD No. 705) and Raymond James Financial Services, Inc. (CRD No. 6694)

On January 31, 2024, the Banking Commissioner entered a Consent Order (No. CO-24-202326-S) with Connecticut registered broker-dealers Raymond James & Associates, Inc. and Raymond James Financial Services, Inc. of 880 Carillon Parkway, St. Petersburg, Florida 33716. The action was predicated on a coordinated multistate investigation focusing on the firm's charging of unreasonable commissions to retail customers on low principal equity transactions. The Connecticut Uniform Securities Act and its Regulations prohibit the charging of unreasonable commissions for services performed. The Consent Order also alleged that Respondents were remiss in supervising the activities that caused the compliance issue. 

As part of the multistate settlement, Respondents agreed to provide affected customers with calculated restitution acceptable to state regulators. The period covered by the misconduct was July 18, 2018 to July 17, 2023.

The Consent Order directed Respondents from violating Connecticut's securities laws. In addition, the Consent Order fined Respondents $75,000, representing Connecticut’s share of the multistate settlement.