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FINRA Bars Ex-LPL Broker Patrick Coogan: “Reckless Misrepresentation”
Former Baton Rouge, Louisiana-based LPL Financial broker Patrick Coogan (CRD# 4576580) has been barred by the Financial Industry Regulatory Authority (FINRA) in connection to allegations he made reckless misrepresentations to a customer.
According to a Letter of Acceptance, Waiver, and Consent (No. 2018058134301) dated April 2020, Patrick Coogan was associated with LPL Financial as a General Securities Representative when, between September 2013 and May 2016, he “made reckless misrepresentations of material fact in seven agreements he signed in connection with loans his customer… obtained from three banks.” FINRA states that his customer obtained the loans from three banks and pledged assets in his brokerage account as LPL for those loans. FINRA notes that his brokerage account had a principal amount of more than $1 million, and states that the customer “over-pledged the assets of the Account to obtain these loans.”
The banks in question, according to FINRA, “required an agreement signed on behalf of LPL,” agreements that were intended to “perfect the bank’s security interest” in the account’s assets and ensure that the bank would be able to access the assets before the customer’s other creditors if the customer defaulted on his obligations. The findings state that Coogan was the broker on the account and signed the agreements without requesting or obtaining LPL’s approval, and without informing LPL that he had signed them until after the period in question. FINRA states that all of the agreements “contained material misrepresentations,” including that Coogan was authorized to sign on LPL’s behalf, that LPL had noted in its records that the customer’s assets had been pledged to the bank as collateral, and that LPL had not “acknowledged or received notice of any other claim” on the assets.”
On the contrary, FINRA states, he was not authorized to sign the agreements, he had not marked in marked LPL’s books or records to reflect the pledge nor taken any steps to ensure LPL did so, and was aware of other claims against the assets “because he had signed prior control agreements” acknowledging such. FINRA states that these misrepresentations enabled the customer “to improperly obtain multiple loans by over-pledging” the assets in his account. FINRA alleges that Coogan “knew or was reckless in not knowing that the agreements contained misrepresentations,” and that he did not understand or carefully review the agreements before signing. FINRA states that his conduct constituted a violation of FINRA Rule 2010. As a result of the foregoing alleged conduct, he was barred from associating with any FINRA member firm in any capacity.
Patrick Coogan is currently not registered as a broker. His previous registrations include LPL Financial, Morgan Keegan & Company, Multi-Financial Securities Corporation, and IFG Network Securities. He has passed four securities industry qualifying examinations and his BrokerCheck report lists zero state securities licenses. (Information current as of June 4, 2020.)