Investor Alert - New Jersey Bureau of Securities Revokes Licenses of Husband / Wife Brokers

The New Jersey Bureau of Securities recently announced that it has revoked the securities licenses of Richard G. Cody and Jill M. Tramontano, formerly Jill M. Cody. Both were from Neptune, NJ.

If you were a customer of Cody, and you have questions or concerns about the way your brokerage account was handled, contact us to schedule a consultation so we can review your account activity with you.

Mr. Cody was first registered in 1999. However, in early 2013 he was suspended by FINRA for one year because he recommended quantitative and qualitative unsuitable transactions to clients, sent customers misleading and unapproved statements and failed to disclose customer complaints on his U-4.

Meanwhile, his then wife, Jill M. Cody, joined Concorde Investment Services in Spring Lake, NJ in early 2013. She then became the broker of record for the customer accounts previously serviced by her husband. However, according to the default decision entered against Mr. Cody by FINRA in August, 2017 and the letter of acceptance, waiver and consent (“AWC”) agreed to by Mrs. Cody (now Tramontano) in February 2017, the Cody’s never told the clients that Mr. Cody had been suspended. In fact, he continued to communicate with customers, discuss market performance and investment strategy and place orders for customers, using his wife’s access to the firm’s trading system, during the period of his suspension.

The Cody’s scheme was uncovered in 2016 when a former client learned that Mr. Cody had been suspended for most of 2013. She advised FINRA that Mr. Cody had acted as her broker during that time and provided FINRA with emails she had exchanged with Mr. Cody showing he was conducting securities business during his suspension.

FINRA commenced an investigation which revealed that Mr. Cody exchanged emails with clients discussing their accounts, trading strategy and account performance. He even met with clients to review their accounts. FINRA found that Mrs. Cody concealed from the customers the fact that her husband had been suspended.

Cody’s failure to appear at the scheduled disciplinary hearing resulted in FINRA issuing a default order.

Lubiner, Schmidt & Palumbo are experienced securities arbitration, regulatory and employment attorneys. We represent small, medium and large broker dealers and individual brokers. We also represent customers in disputes with their brokers.