MARK DAVID HOLT - FINRA · north oaks, minnesota 55127. 2. holt professional association law firm...

BrokerCheck Report

MARK DAVID HOLT

Section Title

Report Summary

Broker Qualifications

Registration and Employment History

Disclosure Events

CRD# 3150622

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5 - 6

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Page(s)

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MARK D. HOLT

CRD# 3150622

This broker is not currently registered.

Report Summary for this Broker

This report summary provides an overview of the broker's professional background and conduct. Additionalinformation can be found in the detailed report.

Disclosure Events

All individuals registered to sell securities or provideinvestment advice are required to disclose customercomplaints and arbitrations, regulatory actions,employment terminations, bankruptcy filings, andcriminal or civil judicial proceedings.

Are there events disclosed about this broker? Yes

The following types of disclosures have beenreported:

Type Count

Regulatory Event 4

Criminal 1

Customer Dispute 4

Termination 2

Judgment/Lien 1

Investment Adviser RepresentativeInformation

https://www.adviserinfo.sec.gov

The information below represents the individual'srecord as a broker. For details on this individual'srecord as an investment adviser representative,visit the SEC's Investment Adviser PublicDisclosure website at



This broker has passed:

1 Principal/Supervisory Exam

1 General Industry/Product Exam

1 State Securities Law Exam

Registration History

This broker was previously registered with thefollowing securities firm(s):

HARBOUR INVESTMENTS, INC.CRD# 19258NORTH OAKS, MN02/2007 - 11/2013

B

GENEOS WEALTH MANAGEMENT, INC.CRD# 120894SHOREVIEW, MN08/2005 - 02/2007

B

HARBOUR INVESTMENTS, INC.CRD# 19258MADISON, WI08/2005 - 08/2005

B

www.finra.org/brokercheck User Guidance

1�2020 FINRA. All rights reserved. Report about MARK D. HOLT.


https://adviserinfo.sec.gov/individual/summary/3150622

http://www.finra.org/brokercheck

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Registrations

This section provides the self-regulatory organizations (SROs) and U.S. states/territories the broker is currently registered and licensed with, thecategory of each license, and the date on which it became effective. This section also provides, for every brokerage firm with which the broker iscurrently employed, the address of each branch where the broker works.








Industry Exams this Broker has Passed

This individual has passed 1 principal/supervisory exam, 1 general industry/product exam, and 1 state securities law exam.

This section includes all securities industry exams that the broker has passed. Under limited circumstances, a broker may attain a registrationafter receiving an exam waiver based on exams the broker has passed and/or qualifying work experience. Any exam waivers that the broker hasreceived are not included below.

Exam Category Date

Principal/Supervisory Exams

General Securities Principal Examination 01/29/2002Series 24B

Exam Category Date

General Industry/Product Exams

General Securities Representative Examination 02/10/1999Series 7B

Exam Category Date

State Securities Law Exams

Uniform Combined State Law Examination 12/23/1998Series 66B IA

Additional information about the above exams or other exams FINRA administers to brokers and other securities professionals can be found atwww.finra.org/brokerqualifications/registeredrep/.





www.finra.org/brokerqualifications/registeredrep/



Professional Designations

This section details that the representative has reported 0 professional designation(s).

No information reported.







Registration History

Registration Dates Firm Name CRD# Branch Location

The broker previously was registered with the following firms:

B 02/2007 - 11/2013 HARBOUR INVESTMENTS, INC. 19258 NORTH OAKS, MN

B 08/2005 - 02/2007 GENEOS WEALTH MANAGEMENT, INC. 120894 SHOREVIEW, MN

B 08/2005 - 08/2005 HARBOUR INVESTMENTS, INC. 19258 MADISON, WI

B 08/2000 - 07/2005 LINSCO/PRIVATE LEDGER CORP. 6413 FORT MILL, SC

B 02/1999 - 09/2000 SECURITIES AMERICA, INC. 10205 LAVISTA, NE

Employment History

Employment Employer Name Investment RelatedPosition Employer Location

This section provides up to 10 years of an individual broker's employment history as reported by the individual broker on the most recently filedForm U4.

Please note that the broker is required to provide this information only while registered with FINRA or a national securities exchangeand the information is not updated via Form U4 after the broker ceases to be registered. Therefore, an employment end date of"Present" may not reflect the broker's current employment status.

02/2007 - Present HARBOUR INVESTMENTS INC REGISTEREDREPRESENTATIVE

Y MADISON, WI, United States

09/1998 - Present HOLT PROFESSIONAL ASSOCIATION OWNER N SHOREWOOD, MN, UnitedStates

09/1998 - Present THE HARBOR GROUP LLC AGENT Y NORTH OAKS, MN, UnitedStates

Other Business Activities

This section includes information, if any, as provided by the broker regarding other business activities the broker is currently engaged in either asa proprietor, partner, officer, director, employee, trustee, agent or otherwise. This section does not include non-investment related activity that isexclusively charitable, civic, religious or fraternal and is recognized as tax exempt.

1. THE OWNER OF HARBOR GROUP INC. AN INVESTMENT RELATED BUSINESS LOCATED AT 200 VILLAGE CENTER DRIVE, SUITE 700,NORTH OAKS, MINNESOTA 55127. 2. HOLT PROFESSIONAL ASSOCIATION LAW FIRM ATTORNEY, WHICH IS NOT AN INVESTMENTRELATED BUSINESS, AND IS LOCATED AT 200 VILLAGE CENTER DRIVE, SUITE 700, NORTH OAKS, MINNESOTA 55127. MR. HOLT IS ALICENSED ATTORNEY IN THE STATE OF MN AND IS THE SOLE OWNER OF HOLT PROFESSIONAL ASSOCIATION AND HAS OPERATEDTHIS LAW OFFICE SINCE 10/01/1997. APPROXIMATELY 110 HOURS/MONTH ARE DEVOTED TO ESTATE PLANNING ADVICE RENDEREDCLIENTS. 3. INDEPENDENT INSURANCE AGENT.







Other Business Activities, continued

1. THE OWNER OF HARBOR GROUP INC. AN INVESTMENT RELATED BUSINESS LOCATED AT 200 VILLAGE CENTER DRIVE, SUITE 700,NORTH OAKS, MINNESOTA 55127. 2. HOLT PROFESSIONAL ASSOCIATION LAW FIRM ATTORNEY, WHICH IS NOT AN INVESTMENTRELATED BUSINESS, AND IS LOCATED AT 200 VILLAGE CENTER DRIVE, SUITE 700, NORTH OAKS, MINNESOTA 55127. MR. HOLT IS ALICENSED ATTORNEY IN THE STATE OF MN AND IS THE SOLE OWNER OF HOLT PROFESSIONAL ASSOCIATION AND HAS OPERATEDTHIS LAW OFFICE SINCE 10/01/1997. APPROXIMATELY 110 HOURS/MONTH ARE DEVOTED TO ESTATE PLANNING ADVICE RENDEREDCLIENTS. 3. INDEPENDENT INSURANCE AGENT.






Disclosure Events

What you should know about reported disclosure events:

1. All individuals registered to sell securities or provide investment advice are required to disclose customer complaints and arbitrations,regulatory actions, employment terminations, bankruptcy filings, and criminal or civil judicial proceedings.

2. Certain thresholds must be met before an event is reported to CRD, for example: o A law enforcement agency must file formal charges before a broker is required to disclose a particular criminal event. o A customer dispute must involve allegations that a broker engaged in activity that violates certain rules or conduct governing the

industry and that the activity resulted in damages of at least $5,000. o

3. Disclosure events in BrokerCheck reports come from different sources: o As mentioned at the beginning of this report, information contained in BrokerCheck comes from brokers, brokerage firms and

regulators. When more than one of these sources reports information for the same disclosure event, all versions of the event willappear in the BrokerCheck report. The different versions will be separated by a solid line with the reporting source labeled.

o4. There are different statuses and dispositions for disclosure events:

o A disclosure event may have a status of pending, on appeal, or final.§ A "pending" event involves allegations that have not been proven or formally adjudicated.§ An event that is "on appeal" involves allegations that have been adjudicated but are currently being appealed.§ A "final" event has been concluded and its resolution is not subject to change.

o A final event generally has a disposition of adjudicated, settled or otherwise resolved.§ An "adjudicated" matter includes a disposition by (1) a court of law in a criminal or civil matter, or (2) an administrative

panel in an action brought by a regulator that is contested by the party charged with some alleged wrongdoing.§ A "settled" matter generally involves an agreement by the parties to resolve the matter. Please note that brokers and

brokerage firms may choose to settle customer disputes or regulatory matters for business or other reasons.§ A "resolved" matter usually involves no payment to the customer and no finding of wrongdoing on the part of the

individual broker. Such matters generally involve customer disputes.

For your convenience, below is a matrix of the number and status of disclosure events involving this broker. Further informationregarding these events can be found in the subsequent pages of this report. You also may wish to contact the broker to obtain furtherinformation regarding these events.

Final On AppealPending

Regulatory Event 0 4 0

Criminal 0 1 0

Customer Dispute 1 3 N/A

Termination N/A 2 N/A

Judgment/Lien 1 N/A N/A






Disclosure Event Details

When evaluating this information, please keep in mind that a discloure event may be pending or involve allegations that are contested and havenot been resolved or proven. The matter may, in the end, be withdrawn, dismissed, resolved in favor of the broker, or concluded through anegotiated settlement for certain business reasons (e.g., to maintain customer relationships or to limit the litigation costs associated with disputingthe allegations) with no admission or finding of wrongdoing.

This report provides the information exactly as it was reported to CRD and therefore some of the specific data fields contained in the report maybe blank if the information was not provided to CRD.

Regulatory - Final

This type of disclosure event may involve (1) a final, formal proceeding initiated by a regulatory authority (e.g., a state securities agency, self-regulatory organization, federal regulatory such as the Securities and Exchange Commission, foreign financial regulatory body) for a violation ofinvestment-related rules or regulations; or (2) a revocation or suspension of a broker's authority to act as an attorney, accountant, or federalcontractor.

Disclosure 1 of 4

Reporting Source: Regulator

Regulatory Action InitiatedBy:

UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Sanction(s) Sought: Bar

Date Initiated: 11/17/2016

Docket/Case Number: 3-17685

Employing firm when activityoccurred which led to theregulatory action:

Geneos Wealth Management, Inc.; Harbour Investments, Inc.

Product Type: Mutual FundOther: unspecified securities

Allegations: SEC Admin Release 34-79338, IA Release 40-4569, November 17, 2016:The Securities and Exchange Commission ("Commission") deems it appropriateand in the public interest that public administrative proceedings be, and herebyare, instituted pursuant to Section 15(b) of the Securities Exchange Act of 1934("Exchange Act") and Section 203(f) of the Investment Advisers Act of 1940("Advisers Act") against Mark D. Holt ("Respondent" or "Holt"). The Commissionalso deems it appropriate to issue an order of forthwith suspension of Respondentpursuant to Rule 102(e)(2) of the Commission's Rules of Practice [17 C.F.R. §201.102(e)(2)].On April 1, 2014, Holt pleaded guilty to one count of wire fraud in violation of Title18 United States Code, Section 1343 before the United States District Court for theDistrict of Minnesota, in United States v. Mark D. Holt, Crim. Information No. 14-CR-68. On August 14, 2014, a judgment in the criminal case was entered againstHolt. He was sentenced to a prison term of 120 months followed by three years ofsupervised release and ordered to make restitution in the amount of$2,940,982.75. Holt, 47 years old, is currently incarcerated at the Federal PrisonCamp in Duluth, Minnesota (BOP Registry No. 17865-041).The count of the criminal information to which Holt pled guilty alleged, among otherthings, that from in or about September 2005 through January 12, 2014, Holtdefrauded his customers to obtain their property and money. In particular, Holtknowlingly caused an email communication to be transmitted in interstatecommerce via servers in Texas to a customer in Minnesota that would give thecustomer access to false account statements. Holt represented to his brokeragecustomers that he would invest their funds in investment vehicles such as bondfunds and mutual funds. Instead, Holt misappropriated their funds by depositingcustomer checks into a bank account he controlled and using these funds to payfor personal and business expenses. In furtherance of his scheme, Holt lulled hiscustomers into believing that he had purchased various investments for them bysending fraudulent Morningstar customer summaries and creating online customeraccounts using Blueleaf, a web-based portal, that displayed fraudulent accountbalances. Additionally, Holt used misappropriated funds to make monthlypayments to his customers that were intended to appear as interest or annuitypayments.Holt, was at all relevant times, an attorney licensed to practice in the State ofMinnesota. On August 18, 2014, the Supreme Court of the State of Minnesotaissued an order disbarring Holt from the practice of law in the State of Minnesotabased on his conviction for wire fraud.






SEC Admin Release 34-79338, IA Release 40-4569, November 17, 2016:The Securities and Exchange Commission ("Commission") deems it appropriateand in the public interest that public administrative proceedings be, and herebyare, instituted pursuant to Section 15(b) of the Securities Exchange Act of 1934("Exchange Act") and Section 203(f) of the Investment Advisers Act of 1940("Advisers Act") against Mark D. Holt ("Respondent" or "Holt"). The Commissionalso deems it appropriate to issue an order of forthwith suspension of Respondentpursuant to Rule 102(e)(2) of the Commission's Rules of Practice [17 C.F.R. §201.102(e)(2)].On April 1, 2014, Holt pleaded guilty to one count of wire fraud in violation of Title18 United States Code, Section 1343 before the United States District Court for theDistrict of Minnesota, in United States v. Mark D. Holt, Crim. Information No. 14-CR-68. On August 14, 2014, a judgment in the criminal case was entered againstHolt. He was sentenced to a prison term of 120 months followed by three years ofsupervised release and ordered to make restitution in the amount of$2,940,982.75. Holt, 47 years old, is currently incarcerated at the Federal PrisonCamp in Duluth, Minnesota (BOP Registry No. 17865-041).The count of the criminal information to which Holt pled guilty alleged, among otherthings, that from in or about September 2005 through January 12, 2014, Holtdefrauded his customers to obtain their property and money. In particular, Holtknowlingly caused an email communication to be transmitted in interstatecommerce via servers in Texas to a customer in Minnesota that would give thecustomer access to false account statements. Holt represented to his brokeragecustomers that he would invest their funds in investment vehicles such as bondfunds and mutual funds. Instead, Holt misappropriated their funds by depositingcustomer checks into a bank account he controlled and using these funds to payfor personal and business expenses. In furtherance of his scheme, Holt lulled hiscustomers into believing that he had purchased various investments for them bysending fraudulent Morningstar customer summaries and creating online customeraccounts using Blueleaf, a web-based portal, that displayed fraudulent accountbalances. Additionally, Holt used misappropriated funds to make monthlypayments to his customers that were intended to appear as interest or annuitypayments.Holt, was at all relevant times, an attorney licensed to practice in the State ofMinnesota. On August 18, 2014, the Supreme Court of the State of Minnesotaissued an order disbarring Holt from the practice of law in the State of Minnesotabased on his conviction for wire fraud.

Current Status: Final

Resolution: Order

Resolution Date: 04/13/2017

Sanctions Ordered:

Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?

No

Bar (Permanent)Suspension

Action Appealed To: SEC

Date Appeal filed:

Appeal Limitation Details:






Sanctions Ordered: Bar (Permanent)Suspension

If the regulator is the SEC,CFTC, or an SRO, did theaction result in a finding of awillful violation or failure tosupervise?

No

(1) willfully violated anyprovision of the SecuritiesAct of 1933, the SecuritiesExchange Act of 1934, theInvestment Advisers Act of1940, the InvestmentCompany Act of 1940, theCommodity Exchange Act, orany rule or regulation underany of such Acts, or any ofthe rules of the MunicipalSecurities Rulemaking Board,or to have been unable tocomply with any provision ofsuch Act, rule or regulation?

(2) willfully aided, abetted,counseled, commanded,induced, or procured theviolation by any person ofany provision of theSecurities Act of 1933, theSecurities Exchange Act of1934, the InvestmentAdvisers Act of 1940, theInvestment Company Act of1940, the CommodityExchange Act, or any rule orregulation under any of suchActs, or any of the rules ofthe Municipal SecuritiesRulemaking Board? or

(3) failed reasonably tosupervise another personsubject to your supervision,with a view to preventing theviolation by such person ofany provision of theSecurities Act of 1933, theSecurities Exchange Act of1934, the InvestmentAdvisers Act of 1940, theInvestment Company Act of1940, the CommodityExchange Act, or any rule orregulation under any suchActs, or any of the rules ofthe Municipal SecuritiesRulemaking Board?







Capacities Affected: association with a broker, dealer, investment adviser, municipal securities dealer,municipal advisor, transfer agent, or NRSRO

Duration: Indefinite

Start Date: 04/13/2017

End Date:

Sanction 1 of 3

Sanction Type: Bar (Permanent)

Capacities Affected: participating in any offering of a penny stock



End Date:

Sanction 2 of 3


Capacities Affected: appearing or practicing before the Commission pursuant to Rule 102(e)(2) of theCommission's Rules of Practice

Duration: n/a


Sanction 3 of 3

Sanction Type: Suspension






Regulator Statement IT IS ORDERED, on November 17, 2016, that Mark D. Holt is forthwith suspendedfrom appearing or practicing before the Commission pursuant to Rule 102(e)(2) ofthe Commission's Rules of Practice.

SEC Admin Release 34-80459, IA Release 40-4686, April 13, 2017:Respondent has submitted an Offer of Settlement (the "Offer") which theCommission has determined to accept.It is ORDERED that Holt is barred from association with any broker, dealer,investment adviser, municipal securities dealer, municipal advisor, transfer agent,or nationally recognized statistical rating organization.Holt is also barred from participating in any offering of a penny stock, including:acting as a promoter, finder, consultant, agent or other person who engages inactivities with a broker, dealer or issuer for purposes of the issuance or trading inany penny stock, or inducing or attempting to induce the purchase or sale of anypenny stock.


End Date:

Disclosure 2 of 4

i



FINRA

Sanction(s) Sought: Suspension


Docket/Case Number: 14-00954


N/A

Product Type: No Product

Allegations: Respondent Holt failed to comply with an arbitration award or settlementagreement or to satisfactorily respond to a FINRA request to provide informationconcerning the status of compliance.


Resolution: Letter






https://www.finra.org/arbitration-mediation/arbitration-awards-online?search=14-00954



Sanctions Ordered:


No

Suspension


No








Regulator Statement Pursuant to Article VI, Section 3 of FINRA By-Laws, and FINRA Rule 9554,Respondent Holt is suspended on February 2, 2016 for failure to comply with anarbitration award or settlement agreement or to satisfactorily respond to a FINRArequest to provide information concerning the status of compliance.



Capacities Affected: any capacity

Duration: N/A


End Date:

Sanction 1 of 1







Regulator Statement Pursuant to Article VI, Section 3 of FINRA By-Laws, and FINRA Rule 9554,Respondent Holt is suspended on February 2, 2016 for failure to comply with anarbitration award or settlement agreement or to satisfactorily respond to a FINRArequest to provide information concerning the status of compliance.

Disclosure 3 of 4

i



FINRA

Sanction(s) Sought: Suspension


Docket/Case Number: 2013038983901


N/A


Allegations: RESPONDENT MARK DAVID HOLT FAILED TO RESPOND TO FINRAREQUEST FOR INFORMATION.


Resolution: LETTER


Sanctions Ordered:


No

Bar (Permanent)


No







Regulator Statement PURSUANT TO FINRA RULE 9552(H) AND IN ACCORDANCE WITH FINRA'SINTENT TO SUSPEND AND NOTICE OF SUSPENSION LETTERS DATEDJANUARY 17, 2014 AND FEBRUARY 10, 2014, RESPECTIVELY, ON APRIL 21,2014 HOLT IS BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER INANY CAPACITY. RESPONDENT FAILED TO REQUEST TERMINATION OF HISSUSPENSION WITHIN THREE MONTHS OF THE DATE OF THE NOTICE OFINTENT TO SUSPEND; THEREFORE, HE IS AUTOMATICALLY BARRED FROMASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY.


Capacities Affected: All Capacities



End Date:

Sanction 1 of 2


Capacities Affected: ANY CAPACITY

Duration: N/A


End Date: 04/20/2014

Sanction 2 of 2







Disclosure 4 of 4

i

Reporting Source: Broker


STATE OF MINNESOTA COMMISSIONER OF COMMERCE

Sanction(s) Sought: Civil and Administrative Penalt(ies) /Fine(s)

Other Sanction(s) Sought:


Docket/Case Number: INSURANCE LICENSE #20154316


LINSCO PRIVATE LEDGER

Product Type: Annuity(ies) - Variable

Other Product Type(s):

Allegations: RESPONDENT IMPROPERLY HAD SEVERAL CLIENTS SIGN PARTIALLYCOMPLETED OR BLANK ANNUITY FORMS, SOLD UNSUITABLE PRODUCTSTO 2 CLIENTS AND FAILED TO DELIVER 2 CLIENT CONTRACTS TIMELY,INVIOLATION OF MINN STAT 45.027, SUBD 7(A)(4);60K.46, SUBD 4 & 72A.20SUBD. 18(B)(2006) AND MINN RULE 2795.0400(2005)


Resolution: Consent


Sanctions Ordered:

Other Sanctions Ordered:

Sanction Details: RESPONDENT ORDERED TO PAY FINE OF $5000.00 BY CONSENT ORDER.

Broker Statement RESPONDENT ALWAYS DENIED SELLING UNSUITABLE PRODUCTS ANDFAILING TO DELIVER CLIENT CONTRACTS.

Monetary/Fine $5,000.00






Criminal - Final Disposition

This type of disclosure event involves a criminal charge against the broker that has resulted in a conviction, acquittal, dismissal, or plea. Thecriminal matter may pertain to any felony or certain misdemeanor offenses, including bribery, perjury, forgery, counterfeiting, extortion, fraud, andwrongful taking of property.

Disclosure 1 of 1


Charge Date: 02/19/2014


Status Date: 08/14/2014

Name of Court: U.S. District Court for the District of Minnesota

Location of Court: Minnesota

Docket/Case #: 0:14cr68

Formal Charges werebrought in:

Federal Court

Disposition Date: 08/14/2014

Sentence/Penalty: On August 14, 2014 Holt was committed to the custody of the United StatesBureau of Prisons to be imprisoned for a total term of 120 months. Upon releasefrom imprisonment, the defendant shall be on supervised release for a term of 3years. The defendant shall make restitution in the amount of $2,940,982.75.

FormalCharge(s)/Description:

Wire Fraud

No of Counts: 1

Felony or Misdemeanor: Felony

Plea for each charge: guilty

Disposition of charge: Pled guilty

Charge(s) 1 of 1

iReporting Source: Firm

Name of Court: UNITED STATES DISTRICT COURT

Location of Court:

Formal Charges werebrought in:

Federal Court






Charge Date: 03/07/2014


Status Date: 04/01/2014

Location of Court: DISTRICT OF MINNESOTA

Docket/Case #: CR14-685RN


Sentence/Penalty: A NON-PUBLIC PLEA AGREEMENT WAS ESTABLISHED ON 04/01/2014.

FormalCharge(s)/Description:

WIRE FRAUD

No of Counts: 1

Felony or Misdemeanor: Felony

Plea for each charge: GUILTY

Disposition of charge: Pled guilty

Charge(s) 1 of 1






Customer Dispute - Award / Judgment

This type of disclosure event involves a final, consumer-initiated, investment-related arbitration or civil suit containing allegations of sales practiceviolations against the broker that resulted in an arbitration award or civil judgment for the customer.

Disclosure 1 of 2


Employing firm whenactivities occurred which ledto the complaint:

Allegations:

Harbour Investments, LLC, Geneos Wealth Management, Inc.,

Mark David Holt was named in a customer complaint that asserted the followingcauses of action: breach of fiduciary duty, gross negligence, violations of federalsecurities laws, violations of state securities laws, respondeat superior, violation ofthe Minnesota Consumer Protection Act, conversion, intentional infliction ofemotional distress, and money had and received. The causes of action related toClaimants' allegation that Holt mismanaged their accounts, including therecommendation to purchase a Jackson Life Annuity, resulting in surrender costsfrom the liquidation of a Hartford Annuity. Claimants further alleged that the firmsfailed to properly supervise Holt, allowing Holt to steal Claimants' funds andprovide false account statements to Claimants.

Product Type: Other: Life Annuity

Alleged Damages: $100,000.00

Arbitration/Reparation Claimfiled with and Docket/CaseNo.:

FINRA - CASE #15-00680

Date Notice/Process Served: 03/24/2015

Arbitration Pending? No

Disposition: Award


Disposition Detail: Mark David Holt is liable for and shall pay to a Claimant the sum of $159,389.86 incompensatory damages, plus interest, and shall pay the sum of $100,000.00 inpunitive damages to this Claimant. Also, Mark David Holt is liable for and shall payto the other Claimant the sum of $118,255.74 in compensatory damages, plusinterest, and shall pay the Claimant the sum of $100,000.00 in punitive damages.

Arbitration Information

iReporting Source: Firm








Allegations:

GENEOS WEALTH MANAGEMENT, INC., HARBOUR INVESTMENTS, INC.

CLAIMANTS ALLEGE HOLT CONVERTED FUNDS FOR PERSONAL USE ANDBREACH OF FIDUCIARY DUTY, GROSS NEGLIGENCE, AND VIOLATION OFSTATE AND FEDERAL SECURITIES LAWS.

Product Type: Annuity-Variable




Disposition: Award to Customer


Monetary CompensationAmount:

$477,645.60

Firm Statement Harbour settled for the amount of $125,000 {Customer} and $50,000 [Customer].Mark David Holt is liable for and shall pay to a Claimant the sum of $159,389.86 incompensatory damages, plus interest, and shall pay the sum of $100,000.00 inpunitive damages to this Claimant. Also, Mark David Holt is liable for and shall payto the other Claimant the sum of $118,255.74 in compensatory damages, plusinterest, and shall pay the Claimant the sum of $100,000.00 in punitive damages.


Individual ContributionAmount:

$0.00

Alleged Damages AmountExplanation (if amount notexact):

DAMAGE REQUEST IN EXCESS OF $100,000.00 TO BE DETERMINED ATHEARING.

Arbitration/CFTC reparationclaim filed with (FINRA, AAA,CFTC, etc.):

FINRA DISPUTE RESOLUTION-ARBITRATION

Docket/Case #: 15-00680

Disclosure 2 of 2

i

Reporting Source: Firm


HARBOUR INVESTMENTS, INC, LINSCO PRIVATE LEDGER, GENEOSWEALTH








Allegations:

HARBOUR INVESTMENTS, INC, LINSCO PRIVATE LEDGER, GENEOSWEALTH

CLIENTS ALLEGE NEGLIGENCE, BREACH OF FIDUCIARY DUTY, CIVILTHEFT, CONVERSION, UNJUST ENRICHMENT, MONEY HAD AND RECEIVED,NEGLIGENT MISREPRESENTATION, VIOLATION OF STATE AND FEDERALSTATUTES.


Alleged Damages: $1,448,500.00



Disposition: Award to Customer



$497,189.18



$0.00


FINRA DISPUTE RESOLUTION








Customer Dispute - Settled

This type of disclosure event involves (1) a pending consumer-initiated, investment-related arbitration or civil suit that contains allegations of salespractice violations against the broker; or (2) a pending, consumer-initiated, investment-related written complaint containing allegations that the

Disclosure 1 of 1



Allegations:

GENEOS WEALTH MANAGEMENT, INC / HARBOUR INVESTMENTS, INC.

CLAIMANTS ALLEGE HOLT CONVERTED THEIR FUNDS FOR HIS PERSONALUSE AND IN DOING SO, BREACHED HIS FIDUCIARY DUTY, WAS GROSSLYNEGLIGENT, AND VIOLATED BOTH STATE AND FEDERAL SECURITIES LAWS.





Disposition: Settled



$85,000.00



$0.00


AMOUNT OF $540,000 IS APPROXIMATE - STATEMENT OF CLAIM ISUNCLEAR AS TO SPECIFIC AMOUNT OF DAMAGES.


FINRA








Customer Dispute - Pending

This type of disclosure event involves (1) a pending consumer-initiated, investment-related arbitration or civil suit that contains allegations of salespractice violations against the broker; or (2) a pending, consumer-initiated, investment-related written complaint containing allegations that thebroker engaged in, sales practice violations resulting in compensatory damages of at least $5,000, forgery, theft, or misappropriation, orconversion of funds or securities.

Disclosure 1 of 1



Allegations:

Geneos Wealth Management, Harbour Investments, Inc.

Client alleges she suffered losses due to negligence, breach of fiduciary duty,fraudulent non-disclosure and failure to properly supervise.


Alleged Damages: $0.00

Date Complaint Received: 08/16/2016

Complaint Pending? Yes

Settlement Amount:


Customer Complaint Information

Civil Litigation Information


in excess of $50,000.00 to be determined at trial

Is this an oral complaint? No

Is this a written complaint? Yes

Is this an arbitration/CFTCreparation or civil litigation?

Yes

Arbitration/Reparation forumor court name and location:

State of Minnesota, County of Becker, Seventh District

Docket/Case #: 03-CV-16-2189

Filing date ofarbitration/CFTC reparationor civil litigation:

08/16/2016







Litigation Pending? Yes

Firm Statement The complaint was settled in the amount of $325,000 on 12/1/2016 in regards toallegations against Harbour. The case is still pending against the rep.

Civil Litigation Information

Type of Court: State Court

Name of Court: State of Minnesota - Seventh District

Location of Court: Becker County

Docket/Case #: 03-CV-16-2189






Employment Separation After Allegations

This type of disclosure event involves a situation where the broker voluntarily resigned, was discharged, or was permitted to resign after beingaccused of (1) violating investment-related statutes, regulations, rules or industry standards of conduct; (2) fraud or the wrongful taking ofproperty; or (3) failure to supervise in connection with investment-related statutes, regulations, rules, or industry standards of conduct.

Disclosure 1 of 2


Employer Name: HARBOUR INVESTMENTS, INC

Termination Type: Discharged

Termination Date: 11/08/2013

Allegations: THE FIRM WAS NOTIFIED BY A FORMER CUSTOMER ABOUT THE RECEIPTOF A CHECK FROM AN UNAUTHORIZED ENTITY APPARENTLY ASSOCIATEDWITH THE REGISTERED REPRESENTATIVE. UPON FURTHERINVESTIGATION, IT APPEARS CURRENTLY THAT ANOTHER CHECK FROMTHE CUSTOMER HAD BEEN DIVERTED BY THE REGISTEREDREPRESENTATIVE FROM HARBOUR AS PAYEE TO ANOTHER ACCOUNTWHICH IS NOT CONNECTED WITH HARBOUR INVESTMENTS. HARBOUR,DURING THE COURSE OF THE TIME PERIOD FROM NOVEMBER 1, 2013 TOTHE CURRENT DATE, HAS BEEN INVESTIGATING THE MATTER AND TRIEDTO CONDUCT A SURPRISE AUDIT OF THE REPRESENTATIVE'S OFFICE ONNOVEMBER 7, 2013, BUT WAS UNABLE TO DO SO. A LAWSUIT WAS ALSOFILED TO FREEZE THE ACCOUNTS OF THE UNAUTHORIZED ENTITY


Disclosure 2 of 2

i


Employer Name: LINSCO PRIVATE LEDGER



Allegations: REPRESENTATIVE MAINTAINED BLANK SIGNED DOCUMENTS INCUSTOMER FILES.


Other Product Types:

iReporting Source: Broker






Employer Name: LINSCO PRIVATE LEDGER



Allegations: ALLEGED VIOLATION OF FIRM PROCEDURES REGARDING PROHIBITIONAGAINST RETENTION OF BLANK SIGNED DOCUMENTS; POSSIBLERESOLUTION OF CUSTOMER COMPLAINT WITHOUT PRIOR NOTIFICATIONTO LINSCO PRIVATE LEDGER LEGAL DEPARTMENT

Product Type: Other

Other Product Types:

Broker Statement WRITTEN STATEMENT FROM CUSTOMER IN QUESTION PROVIDED TOLINSCO PRIVATE LEDGER DENYING EXISTENCE OF ANY COMPLAINT






Judgment / Lien

This type of disclosure event involves an unsatisfied and outstanding judgments or liens against the broker.

Disclosure 1 of 1

Reporting Source: Broker

Judgment/Lien Amount: $51,361.00

Judgment/Lien Holder: IRS

Judgment/Lien Type: Tax

Date Filed: 02/01/2004

Judgment/Lien Outstanding? Yes

Court Details: N/A






End of Report

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MARK DAVID HOLT - FINRA · north oaks, minnesota 55127. 2. holt professional association law firm...

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