As shown by Mr. Starke’s FINRA Brokercheck report, found here, in the last two years customers have filed seven complaints against Mr. Starke, most involving allegations of the sale of illiquid, unsuitable, and high-risk investments.

Alternative Investments, which include REITs (Real Estate Investment Trusts), are often sold as an alternative to more traditional stocks, bonds, and stock and bond funds. These higher-risk investments are often touted for their high returns, especially in a low interest rate environment, however those high returns are accompanied with corresponding high risk.

In addition to their often high-risk nature, alternative investments may also have significant liquidity risk. Because they are typically not traded on an exchange, investors may not be able to determine the actual value of the investment, and further if the investment experiences problems, investors may not be able to sell or otherwise get out of the problem investment.

Pursuant to the Virginia Securities Act, financial advisors are required to disclose the risks associated with investments that are being recommended, and the Act provides for an award of rescission or losses, interest, and reasonable attorneys fees.

Prior to recommending the purchase of specific investments or a specific investment strategy to a customer, a stockbroker / financial advisor such as Mr. Starke is required to determine that the investments are suitable to that particular investor (or in the “best interest” of the customer after 2020). A suitability determination is based upon many different factors such as age, investment objectives, risk tolerance, employment situation, needs, income, assets, and investment experience. If an advisor’s recommendations of unsuitable investments result in the investor incurring significant losses, that investor may have a suitability, negligence, and breach of contract claim against the broker and his/her firm.

Generally, retirees and those on a fixed income should not have their life savings concentrated in high-risk illiquid investments due to the risk of loss as well as the difficulties of selling the investments.

Greco & Greco’s local Virginia-based lawyers have been representing Virginia residents for decades in claims against their financial advisors and brokerage firms. If you have suffered losses in unsuitable high-risk and illiquid investments and wish to discuss your potential claims with a local lawyer, please contact Scott Greco for a free attorney consultation about your potential case.

Greco & Greco is investigating investor losses in the following alternative investments:

• GWG L Bonds
• Moody National REIT
• Mobile Infrastructure
• Parking REIT
• Necessity Retail REIT
• American Finance Trust
• Silver Star Properties REIT
• First Capital Real Estate Trust
• Priority Income Fund
• American Hospitality Properties Fund
• Phoenix American Hospitality
• Commonwealth Capital
• Hospitality Investors Trust
• American Realty Capital Hospitality Trust

The AWC discussed the fact that Janney’s supervisory system red flagged these concentrations, but Janney “failed to take reasonable steps to understand the potential risks and rewards.”

In addition to being censured by FINRA, Janney was fined $100,000 and ordered to pay restitution to the customers that had not yet received restitution in the total amount of $145,019.

Concentration of customer accounts in one sector such as energy, or in multiple master limited partnerships (MLPs), can result in an unsuitable risk in customer accounts, and also may violate Regulation Best Interest (Reg BI). Firms such as Janney are required to have in place reasonable systems to supervise their advisors and accounts to attempt to prevent such violations.

If you have lost monies resulting from unsuitable overconcentration in a single sector, in oil and gas, or in unsuitable MLPs, we may be able to help. Please contact our securities fraud lawyers at Greco & Greco for a free attorney consultation.

The letter alleges that Mr. Turley has been registered with J.P. Morgan Securities LLC since 2009, and that he was terminated by J.P. Morgan in 2021 for “[l]oss of confidence concerning adherence to firm policies and brokerage order handling requirements.” According to FINRA, Mr. Turley has had five FINRA multi-million dollar arbitrations filed in 2020 – 2021 relating to allegations regarding sales practice violations and unsuitable trading. One of these resulted in an arbitration award.

Mr. Turley apparently refused to provide on the record testimony to FINRA in response to a Rule 8210 Request.

Investors who lost money as a result of wrongful conduct (including unsuitable trades, unauthorized trades, or churning) at J.P. Morgan or other firms should contact securities attorney W. Scott Greco for a free consultation about your potential case. Greco & Greco, Securities Fraud Lawyers, represent harmed investors across the country in cases against their financial advisors and firms.