September 27, 2023
Elba M. Nogueras submitted an Acceptance, Waiver, and Consent (AWC). Without admitting or denying the claims, Nogueras accepts and consents to the following findings: Recommending that her customer invest 81% of his liquid net worth with a non-traded REIT without a reasonable basis to believe the investment was in the customer’s best interest. Nogueras consented to a suspension, fine, and disgorgement.
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