FINRA Sanctions Former Broker for Undisclosed Private Equity and Securities Activities

Posted on May 29th, 2025 at 9:51 AM
FINRA Sanctions Former Broker for Undisclosed Private Equity and Securities Activities

From the desk of Jim Eccleston at Eccleston Law

FINRA has sanctioned former registered representative Thomas A. Rapp for engaging in undisclosed outside business and private securities transactions while associated with M Holdings. The enforcement action stems from a Letter of Acceptance, Waiver and Consent (AWC) Rapp submitted under FINRA Rule 9216, resolving the matter without admitting or denying FINRA’s findings.

According to the AWC, between June 2021 and July 2023, Rapp co-founded a private equity fund and served as its chief executive officer and managing partner. Throughout this period, he failed to provide his firm with prior written notice of his involvement, violating FINRA Rules 3270 and 2010. Additionally, Rapp participated in a private offering of limited partnership interests in the fund without notifying M Holdings, in violation of FINRA Rules 3280 and 2010.

The offering, conducted under Regulation D of the Securities Act of 1933, raised over $11 million from roughly 15 investors — several of whom were Rapp’s clients at M Holdings. Rapp directly communicated with prospective investors, signed subscription agreements, and executed regulatory filings related to the offering. Although he did not earn commissions from these transactions, the AWC states that his participation outside of the firm’s oversight triggered regulatory action.

As a result, FINRA imposed a 21-month suspension from associating with any FINRA member in any capacity and levied a $20,000 fine against Rapp. The fine becomes payable upon any future reassociation with a FINRA member or if he applies for relief from statutory disqualification. Rapp also waived any claim of financial hardship to avoid monetary sanction.

While Rapp is not currently associated with a FINRA member, he remains subject to FINRA’s jurisdiction under Article V, Section 4 of its By-Laws. The sanctions will take effect on a date determined by FINRA.

 

Eccleston Law LLC represents investors and financial advisors nationwide in securities, employment, transition, regulatory, and disciplinary matters.

Tags: eccleston, eccleston law, finra

Return to Archive

TESTIMONIALS

Previous
Next

I want to thank you for your excellent professional representation. It was greatly appreciated.

Michael M.

LATEST NEWS AND ARTICLES

November 7, 2025
FINRA Suspends Former Wells Fargo Broker Over Unapproved Real Estate Venture

The Financial Industry Regulatory Authority (FINRA) suspended former Wells Fargo broker George J. Cairnes for four months and fined him $25,000 for engaging in unapproved real estate outside business activity, according to a settlement letter issued.

November 6, 2025
Former Ameriprise Broker Ordered to Pay $2.2 Million for Elder Exploitation

A Financial Industry Regulatory Authority (FINRA) arbitration panel has ordered Eric A. Dupre to pay nearly $2.2 million in damages to his former firm and two customers following allegations of theft and elder exploitation.

November 5, 2025
Former Wells Fargo Representative Suspended for Unauthorized Texting and Obstruction

The Financial Industry Regulatory Authority (FINRA) has suspended former Wells Fargo representative Eyan M. Townsend for one year and fined him $10,000 for using personal text messages to conduct business and attempting to obstruct an internal investigation by deleting those communications.