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2655 South Le Jeune Road
Suite 1108
Coral Gables, FL 33134

Palm Beach County Broker Barred From Securities Industry for Material Misrepresentations

On May 17th, 2018, the National Adjudicatory Council (NAC) affirmed FINRA’s findings and sanctions in the case of Michael Todd Clements (CRD#: 170207), permanently barring the broker from the securities industry and ordering him to pay full financial restitution to affected investors.

The alleged misconduct in this case relates to the period when Mr. Clements was associated with the Avenir Financial Group (CRD#: 148490), a registered broker-dealer based in Wellington, Florida that he owned. In September of 2016, Avenir Financial was expelled from the industry by FINRA.

Here, our Miami investment fraud lawyers review the decision from the NAC. For full details on this case, please refer to FINRA Complaint No. 2015044960501.

Allegations of Misconduct: Michael Todd Clements  


Michael Todd Clements and his partner David Allen formed Avenir Financial Group in 2008. In December 2012, the Financial Industry Regulatory Authority (FINRA) approved the firm’s application for membership. The relevant review period in the case runs from 2013 to 2015, starting almost immediately after the brokerage became a FINRA member firm. During that time, Avenir Financial employed approximately two dozen securities representatives across several branch offices. 

Violative Conduct 

FINRA investigated two separate issues related to this brokerage firm. The first were allegations that the firm was thinly capitalized. The lack of capital to support the firm’s activities put customers at serious financial risk. Indeed, several times during 2013 and 2014, the brokerage firm had issues with insufficient funds.

In addition, FINRA also determined that representatives of this brokerage firm made material misrepresentations to investors. In one example, the firm convinced a 92-year-old investor to put his money into a self-offering made by the broker-dealer. On compliance forms, this investor’s objectives were marked as ‘speculative’ and ‘highly experienced’, even though such strategies were wholly unsuitable for the needs of the investor.

There were other similar examples. Unfortunately, the investors who were sold self-offerings by Avenir Financial were never fully informed about the company’s poor financial health. Quite the contrary; representations were made that indicated that these investors were making reasonably safe investments. 


The NAC panel agreed with FINRA, finding that managing partner Michael Todd Clements was largely responsible for the misconduct that occurred at Avenir Financial Group. It was determined that Mr. Clements violated FINRA Rule 2010 and FINRA Rule 2020. He must be held accountable for the firm’s negligent capital raising activity and the material misrepresentations made to investors.

As a result of the findings, the National Adjudicatory Council (NAC) upheld the decision to bar Michael Todd Clements from the securities industry and ordered him to pay full restitution to the damaged investors. 

Speak to Our Miami Investment Fraud Lawyers Now 

At Carlson & Associates, P.A, our Florida securities attorneys have helped many investors recover full financial compensation for their losses. If you sustained major losses because of your broker’s material misrepresentations or material omissions, we can help. To arrange your confidential consultation, please call our law firm at 1-(305)-372-9700. We look forward to helping you.





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