Green Bay, WI | January 16, 2026
Wisconsin financial advisor Brandon Larsen (CRD# 6192239) was suspended for one month and fined $5,000 by FINRA after regulators found he exercised discretion without written authority in 14 brokerage accounts by executing 165 trades. The enforcement action, finalized on August 13, 2025, came shortly after Larsen was terminated by Thrivent Investment Management Inc. in January 2024 for violating firm policies on unauthorized trading, using unapproved communication channels, and failing to disclose an outside business activity.
According to FINRA’s findings, although customers knowingly permitted Larsen to exercise discretion in their accounts, he failed to obtain their written authorization or his firm’s acceptance of the accounts as discretionary—a fundamental violation of securities industry rules designed to protect investors from unauthorized activity in their accounts.
BrokerCheck Snapshot
Name: Brandon Jerome Larsen
CRD #: 6192239
Firm: Equity Services, Inc.
Location: Green Bay, Wisconsin
Years in Industry: 12
Number of Disclosures: 4
FINRA Enforcement Action: Case #2024081055001
The Violations
On August 13, 2025, FINRA issued an Acceptance, Waiver and Consent (AWC) order detailing Larsen’s violations:
Unauthorized Discretionary Trading
- Exercised discretion in 14 brokerage accounts
- Executed 165 trades without proper written authorization
- Customers knowingly permitted the discretion but lacked required documentation
- Failed to obtain firm acceptance of accounts as discretionary
Product Type: Unspecified Securities
Firm Where Misconduct Occurred: Thrivent Investment Management Inc.
The Sanctions
One-Month Suspension from the securities industry
- Start Date: September 2, 2025
- End Date: October 1, 2025
- Capacity Affected: All capacities
Fine: $5,000 (paid in full on September 5, 2025)
Understanding Discretionary Trading Authority
Discretionary authority allows a broker to make investment decisions on behalf of a client without obtaining specific approval for each transaction. While this can be convenient for some investors, securities regulations impose strict requirements to prevent abuse.
Requirements for Discretionary Accounts
Under FINRA rules, brokers must obtain:
- Written Authorization from the Client – A signed discretionary account agreement specifically granting the broker authority to make trading decisions
- Firm Acceptance – The brokerage firm must review and accept each account as discretionary, typically with enhanced supervision requirements
- Proper Supervision – Firms must establish heightened supervisory procedures for discretionary accounts, including frequent review of trading activity
Why These Rules Exist
The strict requirements for discretionary trading exist to protect investors from:
- Churning – Excessive trading to generate commissions
- Unauthorized trading – Transactions the customer didn’t approve
- Unsuitable investments – Decisions that don’t align with the customer’s objectives
- Abuse of trust – Exploitation of the broker-client relationship
Even when customers verbally agree to give their broker discretion, the written authorization requirement ensures that:
- Customers understand what authority they’re granting
- The scope of discretion is clearly defined
- A documented record exists of the agreement
- The firm can implement proper supervision
Larsen’s Explanation: Dollar-Cost Averaging Strategy
In his statement to regulators, Larsen provided his perspective on the discretionary trading allegations, claiming the violations resulted from misunderstanding firm policies rather than intentional misconduct.
The Dollar-Cost Averaging Approach
According to Larsen’s statement:
“In 2022 and 2023 there was a lot of market volatility so with a few clients who moved money over to Thrivent into Thrivent S shares (no load funds) I talked to them about risk of dumping right into the markets and risking the markets falling, a few clients wanted to be dollar cost averaged into the markets.”
Larsen explained that he:
- Allocated clients to investment models matching their risk tolerance
- Agreed to systematically transfer funds from money market to invested portfolios
- Made purchases on days when the S&P 500 moved negative
- Intended to “smooth out the risk” as clients invested their money
The Compliance Failure
Larsen’s statement continues:
“Thrivent brought this to my attention that even though it was agreed upon to dollar cost average them into the markets I was suppose to call them before each trade. Thrivent checked with clients and all were happy with trades and fully understood what we agreed upon.”
This admission reveals the core problem: Larsen understood clients wanted systematic investing but failed to recognize that executing trades without specific approval for each transaction—even when following an agreed-upon strategy—constitutes unauthorized discretionary trading without proper authorization.
The “I Didn’t Know” Defense
Larsen’s explanation that he “didn’t think [he] was doing anything against policy” and considered himself “going the extra mile” for clients demonstrates a fundamental misunderstanding of securities regulations. Intent doesn’t matter—the rules requiring written discretionary authorization are absolute, regardless of whether:
- Clients verbally agreed to the strategy
- Clients were happy with the results
- The broker believed he was helping clients
- The trading strategy was sound
Termination from Thrivent: Multiple Policy Violations
Before FINRA’s formal enforcement action, Thrivent Investment Management Inc. terminated Larsen’s employment on January 8, 2024, citing three separate policy violations.
Violation #1: Unauthorized Discretionary Trading
Thrivent concluded that Larsen violated firm policies regarding unauthorized and discretionary trading—the same conduct that led to the FINRA enforcement action.
Violation #2: Electronic Communications Outside Approved Channels
Larsen admitted using personal text messages to communicate with clients rather than Thrivent’s approved Hersey communication platform.
Larsen’s Explanation:
“97% of my book of business is my friends/family/referrals who are now my friends. I text them all to talk about random stuff like sports/family/life/ect. When it was time to set up review I would text them and ask what works best to review and we would set up date for them.”
He claimed he “never conducted business or solicited business in text with clients,” only coordinated meeting dates. However, Thrivent determined that even scheduling client meetings via unauthorized channels violated firm policy.
Why This Matters:
Firms require communications through approved channels to:
- Maintain records of all client interactions (required by SEC/FINRA)
- Monitor for compliance violations
- Protect against disputes about what was discussed
- Ensure supervision of broker-client communications
Using personal text messages circumvents these important safeguards.
Violation #3: Failure to Disclose Outside Business Activity
Larsen failed to disclose forming an LLC (Larsen Restoration LLC) for his house-flipping activities.
Larsen’s Explanation:
“My wife and I have been flipping houses on the side for 14 years. We usually do like one a year… in 2023 we decided we were going to have contractors/friends do the work… our lawyer suggested we open LLC to protect incase something ever happened in the house we don’t get sued… So I completely over looked added the LLC on my U4 as outside business activity.”
While Larsen claimed this was an oversight because “nothing changed,” securities regulations require brokers to disclose all outside business activities and organizations they control, regardless of time commitment or investment-related nature. The LLC created a legal entity that required disclosure.
Larsen’s Response to Termination
Larsen’s statement emphasizes that:
- He “instantly fixed” all issues when brought to his attention
- He took “full responsibility” for the mistakes
- He had “never had any warning or anything in my whole career”
- Clients were satisfied with his service
However, the fact remains that Thrivent found the violations serious enough to terminate his employment after more than 10 years with the firm.
Previous Customer Complaint: Variable Annuity Misunderstanding
Larsen’s BrokerCheck record includes a 2016 customer complaint that was denied but reveals potential communication issues.
The 2016 Complaint
Filed: January 20, 2016
Firm: Thrivent Investment Management Inc.
Product: Variable Annuity
Alleged Damages: $10,074.57
Disposition: Denied (March 22, 2016)
Allegations: Customer alleged he understood he would be receiving interest from his variable annuity contract purchased in October 2014, and that his principal investment would be preserved.
Outcome: The complaint was denied.
Pattern of Communication Issues?
While this complaint was denied and occurred early in Larsen’s career (within 2-3 years of starting), it’s worth noting the allegation involved a customer misunderstanding the features of a variable annuity—a complex insurance product that many investors find confusing.
Combined with the later violations involving:
- Discretionary trading without proper written authorization
- Communications outside approved channels
- Undisclosed outside business activities
A pattern emerges of documentation and communication compliance issues that ultimately led to his termination and FINRA sanction.
Personal Bankruptcy Filing
Larsen’s BrokerCheck record also discloses a Chapter 7 bankruptcy filing in 2019.
Filing Date: July 12, 2019
Court: United States Bankruptcy Court, Green Bay, Wisconsin
Case Number: 19-26806-beh
Disposition: Discharged (November 18, 2019)
While personal bankruptcy doesn’t necessarily indicate professional misconduct, it’s information investors should be aware of when evaluating a broker’s background. The bankruptcy occurred while Larsen was employed at Thrivent and approximately 5-6 years into his securities career.
Current Employment and Outside Activities
Following his termination from Thrivent and FINRA suspension, Larsen joined Equity Services, Inc. on February 21, 2024, where he currently works.
Current Registrations
Equity Services, Inc.
1500 River Pines Drive
Green Bay, WI 54311
Position: Registered Representative
Registered Since: February 21, 2024
Licenses
Larsen holds limited securities licenses:
- Series 6 – Investment Company Products/Variable Contracts Representative (passed September 2013)
- Series 63 – Uniform Securities Agent State Law (passed September 2013)
- SIE – Securities Industry Essentials (passed October 2018)
The Series 6 license is more limited than the Series 7, restricting Larsen to selling mutual funds, variable annuities, and certain other products. He cannot sell individual stocks, bonds, or other securities that would require a Series 7 license.
Current State Licenses: Wisconsin, Utah, Ohio, Michigan
Multiple Outside Business Activities
Larsen’s Form U4 discloses extensive outside business activities:
- Degeneffe Financial – Insurance agent (40 hours per month, during trading hours)
- National Life Group – Insurance agent (40 hours per month, during trading hours)
- Larsen Restoration LLC – House flipping business owner (now disclosed, 0% during trading hours)
- Wealth Point Financial – Insurance agent (90% of time during trading hours)
- P&L Ventures LLC – Rental house/Airbnb owner (50% ownership, not during trading hours)
The fact that Larsen reports devoting significant time to insurance-related activities (including 90% of his time to Wealth Point Financial and 40 hours/month each to Degeneffe Financial and National Life Group) raises questions about:
- Where his primary focus and loyalty lies
- How much time he dedicates to securities business
- Potential conflicts between insurance and securities recommendations
- Whether insurance sales commissions influence his investment advice
These outside activities, which were previously a source of compliance violations, are now properly disclosed but still represent substantial time commitments outside his core securities responsibilities.
The Risks of Discretionary Trading Without Proper Authorization
The violations in Larsen’s case illustrate why securities regulations strictly control discretionary trading.
Investor Vulnerabilities
When brokers exercise discretion without proper authorization and supervision:
Churning Risk – Brokers may trade excessively to generate commissions, knowing clients won’t question each transaction
Loss of Control – Investors lose oversight of their accounts, discovering unexpected positions or activity only when reviewing statements
Suitability Issues – Discretionary authority can lead to investments that don’t match client objectives, risk tolerance, or financial circumstances
Accountability Gaps – Without written agreements defining the scope of discretion, disputes arise about what authority the client actually granted
Inadequate Supervision – Firms can’t properly supervise activity they don’t know is discretionary, increasing risk of abuse
The Documentation Imperative
The requirement for written discretionary authorization serves multiple protective functions:
- Clarity – Both parties understand exactly what authority is granted
- Scope Definition – The agreement specifies limitations on discretionary trading
- Revocability – Clients know how to revoke discretion if circumstances change
- Supervisory Trigger – Written authorization alerts the firm to implement enhanced supervision
- Evidence – Documentation resolves disputes about whether authority was granted
Even well-intentioned arrangements like Larsen’s dollar-cost averaging strategy require proper documentation to ensure investor protection and regulatory compliance.
Recovery Options for Unauthorized Trading Victims
If you experienced unauthorized trading, breach of fiduciary duty, or other misconduct by a broker who exercised discretion without proper authorization, you may be entitled to recover your losses through FINRA arbitration.
Patil Law, P.C. has over 15 years of experience representing investors in FINRA arbitration and securities litigation, with more than $25 million recovered for clients across 1,000+ cases. We provide a free, confidential consultation to review your potential claim. Our firm works on a contingency fee basis, meaning you pay no attorney fees unless we successfully recover money for you.
Understanding FINRA Arbitration
FINRA arbitration is a streamlined dispute resolution process for securities-related claims. It offers a faster, more cost-effective alternative to traditional court litigation. Most cases are resolved within 12-16 months. Claims generally must be filed within six years of the incident.
Unauthorized trading cases can be particularly strong for investors because:
- The lack of written authorization violates clear regulatory requirements
- FINRA enforcement findings can serve as evidence in customer claims
- Firms are responsible for supervising and preventing unauthorized activity
- Damages can include losses, excessive commissions, and emotional distress
Resources for Wisconsin Investors
For more information about complaints and disclosures involving Equity Services, Thrivent, and related cases, see:
- Equity Services Advisors – Complaints & Disclosures
- Thrivent Advisors – Complaints & Disclosures
- Investment Fraud Claims
- Broker Misconduct Cases
- Variable Annuity Fraud
Common Questions About Unauthorized Discretionary Trading
What exactly is discretionary trading authority?
Discretionary authority allows brokers to make buy and sell decisions in customer accounts without obtaining specific approval for each transaction. This includes decisions about which securities to trade, the amount, and the timing. Proper discretionary authority requires written client authorization and firm acceptance, with enhanced supervisory procedures. Without these requirements, the trading becomes unauthorized—even if the client verbally agreed to the strategy.
Can brokers trade my account based on verbal agreements?
No. Securities regulations require written authorization for discretionary trading, regardless of verbal agreements or understandings between broker and client. Even if you tell your broker “go ahead and invest my money as you see fit,” the broker cannot legally execute trades without your specific approval for each transaction unless you’ve signed a discretionary agreement and the firm has accepted the account as discretionary.
How can I tell if my broker is exercising unauthorized discretion?
Warning signs include: trades appearing in your account that you didn’t specifically authorize; your broker making investment decisions without consulting you first; systematic trading patterns that you verbally discussed but never formalized in writing; feeling like your broker is managing your account without seeking your input; or discovering your broker implemented a trading strategy you agreed to conceptually but never approved transaction-by-transaction.
What’s the difference between following investment advice and discretionary trading?
Following advice means your broker recommends specific trades, you approve each one, and the broker then executes your decision. Discretionary trading means the broker makes and implements decisions without seeking your approval for each transaction. The line is crossed when the broker executes trades based on general instructions or strategies rather than specific transaction-by-transaction authorization.
Are there legitimate uses for discretionary accounts?
Yes. Some investors—particularly those who are extremely busy, travel frequently, or prefer professional management—benefit from discretionary arrangements. However, these must be properly documented with written agreements, clearly defined investment parameters, enhanced firm supervision, and regular communication about account activity. Discretionary authority should never be informal or undocumented.
What should I do if I discover unauthorized trading in my account?
Immediately document all unauthorized transactions with dates, amounts, and securities involved. Preserve all account statements, confirmations, and communications with your broker. File a written complaint with both your brokerage firm and FINRA. Cease any further trading activity until the situation is resolved. Consult with an experienced securities attorney to evaluate potential claims. Time limits apply, so don’t delay taking action.
How do I check my broker’s background?
Visit FINRA’s BrokerCheck website at brokercheck.finra.org and search by broker name or CRD number. The free report includes employment history, licenses, customer complaints, regulatory actions, terminations, bankruptcies, and other disclosures. Always check before establishing a relationship with a broker, and review periodically even with existing advisors to catch new disclosures.
About Patil Law, P.C.
Patil Law, P.C. is a securities litigation firm dedicated to representing investors who have suffered losses due to broker misconduct, unauthorized trading, and securities fraud. Founded in 2018 by attorney Chetan Patil, the firm focuses exclusively on FINRA arbitration and investment loss recovery.
With over 15 years of combined experience in securities law, Patil Law has successfully recovered more than $25 million for clients across 1,000+ cases. Attorney Chetan Patil earned his law degree from Case Western Reserve University School of Law. Attorneys Gabriela Dubrocq and Patricia Herrera earned their law degrees from University of Miami. The firm handles cases nationwide involving unauthorized trading, churning, unsuitable investments, breach of fiduciary duty, failure to supervise, and investment fraud.
Patil Law works on a contingency fee basis, meaning clients pay no attorney fees unless the firm successfully recovers money on their behalf. All consultations are free and confidential.
Don’t Let Unauthorized Trading Go Unchallenged
Securities claims are subject to strict time limits. Under FINRA rules, arbitration claims generally must be filed within six years of the investment or the discovery of wrongdoing.
If you were a client of Brandon Larsen at Thrivent or any other firm, or if you’ve experienced unauthorized discretionary trading with another broker, the clock may already be running on your ability to recover.
Call: 800-950-6553
Email: info@patillaw.com
Website: investmentlosslawyer.com
We’re here to help you understand your rights and pursue the compensation you deserve. There is no cost and no obligation for an initial consultation.
Disclaimer: The information in this post is based on FINRA BrokerCheck records and public filings. Allegations described are pending or unproven and may be contested. All investors are entitled to fair treatment under securities laws. This is attorney advertising. Prior results do not guarantee a similar outcome. This communication is for informational purposes only and does not create an attorney-client relationship.