FINRA has suspended Deutsche Bank Securities Inc. broker Garrett Neubart from the securities industry for two months. Mr. Neubart consented to the sanction and to the entry of findings that he engaged in an outside business activity without providing prior written notice to his firm. His suspension is scheduled to begin on September 20, 2021, and end on November 19, 2021.
If you have suffered investment losses with Garrett Neubart, or Deutsche Bank Securities Inc., contact New York securities arbitration lawyers Iorio Altamirano LLP for a free and confidential evaluation of your account.
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FINRA Letter of Acceptance, Waiver, and Consent No. 2019062347901
Garrett Neubart and FINRA entered into a Letter of Acceptance, Waiver, and Consent (“AWC”) on August 23, 2021, after FINRA alleged that from September 2017 through November 2018, while associated with Deutsche Bank, Mr. Neubart violated FINRA Rules 3270 and 2010 by engaging in an outside business activity without providing prior written notice to the firm.
FINRA indicated that the matter originated from a filing by Deutsche Bank under FINRA Rule 4530 in April 2019.
During the relevant period, Deutsche Bank’s written procedures required its associated persons to provide written notice to the firm and receive the firm’s approval prior to engaging in any outside business activities.
From September 2017 through November 2018, Mr. Neubart scheduled and attended meetings between an artificial intelligence (AI) company and his institutional clients at Deutsche Bank in an effort to market the AI company’s products and services to the clients.
In preparation for these meetings, Mr. Neubart, using his Deutsche Bank email address, sent the clients pitch books, marketing decks, and other information on the AI company. During the same period, Mr. Neubart arranged for introductions between the AI company and employees in Deutsche Bank’s Research Department to discuss the AI company’s products and services. In January 2018, as compensation for his efforts, Mr. Neubart received Incentive Units from the AI company for a nominal price, entitling Mr. Neubart to purchase shares of the company for a fixed price at any time of his choosing. Previously, the AI company had only given its employees and contractors the opportunity to own Incentive Units.
Mr. Neubart did not provide prior written notice to or receive approval from Deutsche Bank to engage in outside business activities involving the AI company. In November 2017, Mr. Neubart orally requested approval from Deutsche Bank to engage in outside business activities involving the Al company, but the firm’s Compliance Department told Mr. Neubart he could not engage in any outside activities with the AI company or receive compensation in connection with outside business activities. Mr. Neubart then inaccurately characterized his receipt of Incentive Units from the AI company as a “passive investment” in a disclosure to the firm in December 2017. In addition, on his annual compliance attestations in 2017 and 2018, Mr. Neubart inaccurately certified to the firm that he had disclosed all outside business activities.
Therefore, Mr. Neubart violated FINRA Rules 3270 and 2010.
FINRA stated that in determining the appropriate sanctions in this matter, it considered that Deutsche Bank disciplined Mr. Neubart for his conduct involving the AI company by reducing his 2018 bonus.
FINRA Rules 3270 and 2010
FINRA Rule 3270 provides that “[n]o registered person may be an employee, independent contractor, sole proprietor, officer, director or partner of another person, or be compensated, or have the reasonable expectation of compensation, from any other person as a result of any business activity outside the scope of the relationship with his or her member firm, unless he or she has provided prior written notice to the member, in such form as specified by the member.”
A violation of FINRA Rule 3270 is also a violation of FINRA Rule 2010, which requires associated persons to “observe high standards of commercial honor and just and equitable principles of trade.”
Garrett Scott Neubart (CRD#: 2558442)
Mr. Neubart entered the securities industry in September 2000 when he became registered as a General Securities Representative (GSR) through his association with Goldman, Sachs & Co. He remained with the firm until 2006.
In April 2006, Mr. Neubart became registered as a GSR through his association with Deutsche Bank Securities Inc.
How to Recover Losses or Obtain a Free Consultation
If you have suffered investment losses with Garrett Neubart, or Deutsche Bank Securities Inc., contact New York securities arbitration lawyers Iorio Altamirano LLP toll-free at (855) 430-4010 for a free and confidential evaluation of your account.
Iorio Altamirano LLP is a securities arbitration law firm based in New York, NY. We pursue FINRA arbitration claims nationwide on behalf of investors to recover financial losses arising out of wrongful conduct by financial advisors and brokerage firms.