May 12, 2021
On March 16, 2021, the Financial Industry Regulatory Authority (FINRA) Department of Enforcement approved a Letter of Acceptance, Waiver and Consent (AWC) submitted by Tonya Smoake, a general securities representative formerly associated with Pursche Kaplan Sterling Investments in New York City from March 2017 to May 2019. She was most recently associated with Bhargava Capital in Franklin Lakes, New Jersey from May 2019 to September 2020.
According to the AWC, Smoake allegedly participated in approximately $1.6 million in a registered investment advisor (RIA) and its holding company without providing Pursche prior written notice. Smoake was the chief operations officer of the RIA at the time of these offerings and facilitated the investments by gathering signed documents from investors, answering investor questions, and coordinating investor payments. FINRA also asserts that Smoake falsely stated on the firm’s annual compliance questionnaire that she was not involved in any private securities transactions.
Although none of the customers were associated with Pursche and Smoake did not receive commissions, Smoake violated FINRA Rules 3280 and 2010. By signing the AWC, Smoake consented to a 12-month suspension from associating with any FINRA member firm in all capacities and a $5,000 fine.