STEPHEN A. ROGERS Investment Fraud Investigation: Alternative Investment Allegations

March, 2025 | Based in Columbus, OH

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Important Background on Stephen A. Rogers

• Full Name: Stephen A. Rogers
• CRD Number: 4421548
• Current Location: Columbus, OH
• Current Status: Not currently registered
• Previous Employers: LPL Financial LLC (08/2019-03/2025), Voya Financial Advisors, Inc. (11/2004-08/2019), MONY Securities Corporation (07/2001-11/2004)
• Office Address: Previously at Heartland Bank (Upper Arlington, OH)
• Professional Designations: Certified Financial Planner
• Registration History: Previously registered in multiple states
• Industry Exams: General Securities Representative (Series 7), Investment Company Products/Variable Contracts Representative (Series 6), Securities Industry Essentials (SIE), Uniform Securities Agent State Law (Series 63)
• FINRA BrokerCheck: 1 pending customer dispute
• Ability to Recover Losses: Within FINRA’s 6-year eligibility period for arbitration claims

Recent Allegations of Unsuitable Alternative Investments

Stephen A. Rogers, a former financial advisor most recently affiliated with LPL Financial LLC, is currently facing allegations regarding unsuitable investment recommendations. According to his FINRA BrokerCheck report, a customer has filed a complaint alleging that in or around June 2015, Rogers recommended multiple alternative investments that were illiquid and unsuitable for the customer’s investment objectives and risk tolerance.

The pending FINRA arbitration case (filed in January 2025) centers on allegations that Rogers misrepresented the risks associated with these investments, which reportedly included real estate securities, business development corporations, and limited partnerships. These types of alternative investments typically come with significant liquidity constraints and risk factors that make them appropriate only for certain investor profiles.

Rogers’ Career and Registration History

Stephen A. Rogers began his career in the securities industry in 2001 with MONY Securities Corporation, where he remained until November 2004. He then joined Voya Financial Advisors, Inc., where he worked for nearly 15 years from November 2004 to August 2019. Most recently, Rogers was affiliated with LPL Financial LLC from August 2019 until March 2025.

During his time at LPL Financial, Rogers operated under the business name “Heartland Planning Associates” as a doing-business-as (DBA) entity for his LPL business. He was also associated with Heartland Bank in Upper Arlington, Ohio, where he served as a registered representative.

It’s worth noting that Rogers is no longer registered as a broker, with his registration with LPL Financial LLC having ended in March 2025, shortly after the customer complaint was filed in January 2025. While the timing could be coincidental, it raises questions about whether his departure was related to the pending allegations.

Understanding the Alternative Investments at Issue

The customer complaint against Rogers specifically involves alternative investments, including real estate securities, business development corporations, and limited partnerships. To understand the nature of the allegations, it’s important to recognize the characteristics of these investment types:

Real Estate Securities

Real estate securities, which may include Real Estate Investment Trusts (REITs) and other real estate-focused investment vehicles, can be publicly traded or non-traded. Non-traded REITs in particular present several risk factors:

• Illiquidity: Non-traded REITs typically cannot be sold on a public exchange, making them difficult to liquidate before their maturity date.
• Valuation challenges: Without public market pricing, it can be difficult to determine the actual value of the investment.
• High fees: These products often carry substantial upfront fees that can reach 15% of the investment amount.
• Dividend concerns: Dividends may be paid from borrowed funds or return of principal rather than operating income.

Business Development Companies (BDCs)

BDCs are investment companies that invest in small and mid-sized businesses. They present distinct risks:

• Complex structures: BDCs can be difficult for average investors to understand.
• Credit risk: They often invest in debt securities of companies with lower credit quality.
• Interest rate sensitivity: Changes in interest rates can significantly impact BDC performance.
• Leverage: Many BDCs use borrowed money to enhance returns, which also increases risk.

Limited Partnerships

Limited partnerships are investment vehicles where investors have limited liability but also limited control:

• Lack of control: Limited partners have minimal say in investment decisions.
• Tax complexity: These investments often generate complex tax reporting requirements.
• Exit challenges: There’s typically no established secondary market for selling partnership interests.
• Potential conflicts of interest: General partners may have interests that don’t align with limited partners.

Red Flags in the Customer Complaint

The FINRA complaint against Rogers contains several concerning allegations that represent potential violations of securities regulations:

1. Unsuitable Investment Recommendations

The central allegation is that Rogers recommended investments that were unsuitable for the customer’s investment objectives and risk tolerance. FINRA Rule 2111 (Suitability) requires that financial advisors have a reasonable basis to believe that a recommended investment strategy or transaction is suitable for the customer based on the customer’s investment profile.

2. Misrepresentation of Investment Risks

The customer further alleges that Rogers misrepresented the risks associated with the alternative investments. If proven, this would potentially violate FINRA Rule 2020, which prohibits the use of manipulative, deceptive, or fraudulent devices in connection with securities transactions.

3. Liquidity Concerns

A specific issue noted in the complaint is the illiquid nature of the recommended investments. Recommending illiquid investments without proper disclosure or consideration of a client’s liquidity needs could constitute a breach of fiduciary duty and violation of suitability requirements.

The Timing of the Complaint

An interesting aspect of this case is the timing of the complaint. The investments in question were reportedly made in or around June 2015, but the complaint wasn’t filed until January 2025—nearly a decade later. This timeline suggests several possibilities:

1. The customer may have only recently discovered problems with the investments, possibly as they attempted to liquidate positions.
2. The illiquid nature of the investments might have prevented the customer from recognizing losses until recently.
3. The investments may have had a long maturity period that recently ended, revealing returns below what was represented.

Rogers’ Response to the Allegations

In his response to the complaint, Rogers denies any wrongdoing and asserts that the allegations are without merit. According to his statement in the BrokerCheck report, the investments were “accurately disclosed as carrying risk” when they were purchased in 2015. Rogers also states that the complainant is “an educated professional” who “made informed choices” and “remains a client today.”

This response suggests that Rogers may defend his recommendations on the grounds that:

1. All risk disclosures were properly made
2. The customer was sophisticated enough to understand these risks
3. The continuing client relationship indicates satisfaction with his services overall

The Legal and Regulatory Framework

Several FINRA rules are particularly relevant to the allegations against Stephen A. Rogers:

FINRA Rule 2111 (Suitability)

This rule requires that financial advisors have a reasonable basis to believe that a recommended investment is suitable for the customer based on the customer’s investment profile, which includes:

• Age
• Financial situation
• Tax status
• Investment objectives
• Investment experience
• Risk tolerance
• Time horizon
• Liquidity needs

A key question in this case will be whether the alternative investments recommended were consistent with the customer’s documented investment profile.

FINRA Rule 2020 (Manipulative and Deceptive Practices)

This rule prohibits the use of manipulative, deceptive, or fraudulent devices to effect securities transactions. Allegations of misrepresenting investment risks would fall under this rule.

FINRA Rule 2010 (Standards of Commercial Honor)

This fundamental rule requires brokers to observe high standards of commercial honor and just and equitable principles of trade. It serves as a broad ethical standard against which all broker conduct is measured.

Guidance for Investors with Similar Situations

If you’ve worked with Stephen A. Rogers or another financial advisor who recommended alternative investments that you believe may have been unsuitable, consider taking these steps:

1. Review Your Investment Documents

Gather all documentation related to your investments, including:

• Account opening documents
• Investment confirmations
• Account statements
• Marketing materials
• Disclosure forms
• Communications with your advisor

2. Assess the Suitability of Recommendations

Consider whether the investments recommended were appropriate given your:

• Stated investment objectives
• Risk tolerance
• Financial situation
• Time horizon
• Liquidity needs

3. Understand the Statute of Limitations

FINRA arbitration claims generally must be filed within six years of the event giving rise to the claim. If you’re concerned about investments made several years ago, it’s important to consult with an attorney promptly.

4. Evaluate Potential Misrepresentations

Reflect on how the investments were presented to you:

• Were the risks fully disclosed?
• Were returns presented realistically?
• Was the illiquid nature of the investments explained?
• Were fees and expenses clearly outlined?

5. Consult with a Securities Attorney

An experienced securities fraud attorney can:

• Evaluate the merits of your potential claim
• Explain your options for recovery
• Guide you through the FINRA arbitration process
• Help determine appropriate damages

The FINRA Arbitration Process

If you believe you’ve been harmed by unsuitable investment recommendations, the FINRA arbitration process provides a forum for seeking recovery. Here’s what to expect:

1. Initial Consultation and Case Evaluation

A securities attorney will review your situation to determine if you have grounds for a claim.

2. Filing a Statement of Claim

Your attorney will prepare and file a formal statement of claim with FINRA, outlining your allegations and requested relief.

3. Respondent’s Answer

The broker and/or brokerage firm will have an opportunity to respond to your allegations.

4. Arbitrator Selection

FINRA will provide lists of potential arbitrators, and both sides will participate in selecting the panel that will hear the case.

5. Discovery

Both parties will exchange relevant documents and information.

6. Hearing

At the hearing, both sides will present evidence, testimony, and arguments to the arbitration panel.

7. Decision

The arbitrators will issue a binding decision, typically within 30 days of the hearing.

Potential Recovery for Investment Losses

If a FINRA arbitration claim is successful, investors may be entitled to various forms of compensation:

• Actual damages: The direct financial losses suffered
• Market-adjusted damages: What the portfolio would have earned in suitable investments
• Costs and fees: Attorney’s fees and costs in some circumstances
• Interest: Pre-judgment interest on losses
• Rescission: In some cases, cancellation of the investment and return of principal

The Importance of Due Diligence

The allegations against Stephen A. Rogers highlight the critical importance of conducting thorough due diligence:

1. Check FINRA BrokerCheck: Always verify a broker’s background, including any history of customer complaints or regulatory actions.
2. Research investment products: Before investing, especially in alternative investments, understand the features, risks, and liquidity constraints.
3. Clarify all fees: Ensure you understand all costs associated with an investment, including commissions, management fees, and expenses.
4. Get recommendations in writing: Request that your advisor document why a particular investment is suitable for your specific situation.
5. Consider liquidity needs: Be cautious about tying up significant portions of your portfolio in illiquid investments.

How Securities Attorneys Can Help

If you believe you may have been affected by unsuitable investment recommendations from Stephen A. Rogers or any financial advisor, a securities fraud attorney can provide valuable assistance:

• Case evaluation: Determining the strength of your potential claim
• Regulatory guidance: Explaining relevant FINRA rules and regulations
• Evidence gathering: Helping collect and organize documentation
• Expert analysis: Working with financial experts to analyze your portfolio
• Negotiation: Attempting to reach a favorable settlement
• Representation: Advocating for you throughout the arbitration process

Call 800-950-6553 or complete our online form today to schedule your no-obligation case evaluation. Our investment fraud attorneys are standing by to help you understand your options for recovering potential investment losses.

Chetan Patil

Chetan Patil is the founder and Managing Partner of the Patil Law. He brings over 15 years of extensive experience in diverse complex disputes and transactions, across the country. Mr. Patil specializes in litigations, trials, arbitrations, and appeals of complex securities, FINRA, financial and business disputes, with an emphasis in securities, financial services, and financial regulatory law.