For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority ("FINRA"), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, David E. West submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted. In the Matter of David E. West, Respondent (AWC 2011029524801, July 30, 2014).
In 1996, West first became registered. In 2006 he was registered with Stout Risius Ross Advisors, LLC, ("SRRBD"), a FINRA member broker-dealer, and he was also employed with the firm's parent Stout Risius Ross, Inc., ("SRR"), a financial advisory services firm. The AWC asserts that West had no prior disciplinary history.
The Bare Minimum
The AWC asserts that sometime starting in March 2011, West had several meetings with representatives from an equipment distribution company. Purportedly, West had hoped in persuade the company to hire SRR to provide financial advisory services. Although the company pursued such a relationship, SRR ultimately rejected the engagement because the company would not pay the minimum services fee.
The Pioneer Spirit
After his attempts to put the company and his firm together had failed, West created Pioneer Capital Advisors, LLC (which he also owned and controlled, and was the sole shareholder and employee) through which he provided to the company the services that SRR had declined to provide. The AWC concedes that by offering advisory services to the company through Pioneer that he was "enhancing his relationship" with the company and hopefully facilitating a future financial engagement with himself and SRR.
On July 9, 2011, acting on behalf of Pioneer, West executed an engagement letter to perform advisory services for the company. Thereafter, he traveled to the company's St. Louis, MO facilities in connection with the assignment. Overall, West and Pioneer would receive a total of $16,714.02 in advisory fees and expenses from the company.
At this point, West sort of loses me - or at least his logic and/or thought pattern somewhat eludes me. He submits to SRR a reimbursement request for $569.29 in travel expenses for the trip he took to St. Louis pursuant to the Pioneer engagement letter. SRR paid that expense. In fact, the company had separately paid to West that same travel expense pursuant to the engagement letter. It wound up as a double-dip.
What Part Of "NO" Didn't You Get?
Online FINRA records as of August 7, 2014, indicate that Stout Risius Ross Advisors had "Discharged" West on September 20, 2011, based upon allegations that he had: