Red Bank, NJ | January 23, 2026
Former broker John N. Girgis (CRD# 5021526) has been permanently barred from the securities industry after refusing to appear for on-the-record testimony requested by FINRA. The bar, which became effective September 30, 2025, stems from FINRA’s investigation into Girgis’s outside business activities and trading activity in customer accounts while he was associated with Worden Capital Management LLC and SW Financial.
According to the Acceptance, Waiver and Consent (AWC) agreement, Girgis consented to the permanent bar rather than provide testimony to regulators. The investigation, documented under case number 2019060753512, began in 2019 and concluded with Girgis’s indefinite prohibition from associating with any FINRA member firm in any capacity.
Girgis’s FINRA record also shows two customer disputes—one settled for $14,999 and another where he was dismissed after claiming he was improperly named as a respondent.
BrokerCheck Snapshot
Name: John N. Girgis
CRD #: 5021526
Current Status: Not currently registered
Last Firm: Garden State Securities, Inc. (Red Bank, NJ)
Years in Industry: 20 years (2005-2025)
Number of Disclosures: 3 (1 regulatory event, 2 customer disputes)
The FINRA Bar: Refusing to Cooperate with Regulators
The most serious disclosure on Girgis’s record is his permanent bar from the securities industry, finalized on September 30, 2025. The bar was imposed after Girgis “refused to appear for on-the-record testimony requested by FINRA in connection with an investigation into his outside business activities and his trading activity in the accounts of his member firms’ customers.”
This refusal to testify represents a severe violation of securities industry rules. FINRA Rule 8210 grants the regulator authority to require registered persons to provide information and testimony in connection with investigations. Refusing to comply with such requests typically results in automatic bars from the industry, as it did in Girgis’s case.
The investigation focused on two key areas:
Outside Business Activities – FINRA was examining business activities Girgis engaged in beyond his registered securities work at Worden Capital Management and SW Financial. Brokers are required to disclose all outside business activities to their firms and obtain approval before engaging in them, as such activities can create conflicts of interest or compliance risks.
Customer Account Trading Activity – The investigation also involved Girgis’s trading activity in customer accounts, suggesting regulators had concerns about how he managed client investments or executed transactions.
Rather than provide testimony about these matters, Girgis signed an Acceptance, Waiver and Consent agreement, accepting the permanent bar without admitting or denying the findings. This decision effectively ended his ability to work in the securities industry.
Why Refusing FINRA Testimony Results in Bars
FINRA’s authority to compel testimony and documents is fundamental to its regulatory mission. When brokers refuse to cooperate with investigations, it:
Obstructs Regulatory Oversight – FINRA cannot effectively protect investors if registered persons refuse to answer questions about their conduct.
Suggests Potential Wrongdoing – While refusing testimony doesn’t prove misconduct, it often suggests the individual has information they prefer not to disclose under oath.
Undermines Industry Integrity – The self-regulatory system depends on registered persons’ cooperation with examinations and investigations.
Violates Fundamental Industry Rules – FINRA Rule 8210 makes cooperation with investigations a condition of registration. Refusal to comply means the individual can no longer meet the basic requirements for industry participation.
Permanent bars for refusing testimony are standard practice and are rarely overturned. Unlike bars that can be subject to appeal or later modification, bars for non-cooperation with investigations effectively end a broker’s career in the securities industry.
Customer Disputes: A Pattern of Trading Allegations
In addition to the regulatory bar, Girgis’s record shows two customer disputes involving similar allegations of improper trading practices:
Worden Capital Churning and Fraud Claim (Settled – 2023)
On March 21, 2022, Girgis was named in a mass arbitration claim filed by more than 50 customers through FINRA case #22-00347. The complaint alleged:
- Churning (excessive trading)
- Excessive commissions
- Unauthorized trading
- Unsuitability
- Negligence
- Breach of contract
- Fraud
The case involved over-the-counter equities and listed stocks. Girgis’s portion of the claim involved alleged damages of $210,180.83.
In his broker statement, Girgis denied wrongdoing and characterized the claim as “frivolous,” stating he was “only associated with 3 of the customers at some point in time” out of the 50+ claimants. He criticized the claim as being solicited by what he called a “notorious non-attorney group” that “extorts money out of innocent brokers.”
Despite his denials, the case settled on October 6, 2023, for $14,999, with Girgis personally contributing the entire settlement amount. While brokers sometimes settle claims for business reasons without admitting wrongdoing, a personal contribution to settlement suggests either exposure in the case or a strategic decision to avoid further litigation costs.
SW Financial Multi-Client Claim (Dismissed – 2024)
On March 3, 2023, Girgis was named in another customer arbitration filed with FINRA under case #22-02586. This complaint involved multiple clients and registered representatives at SW Financial, alleging:
- Unsuitability
- Excessive trading and commissions
- Unauthorized trading
- Negligence
The complaint involved over-the-counter equities and listed stocks, with alleged damages attributed to Girgis of $264,475.
However, Girgis maintained he was “improperly named as a respondent” in the arbitration, stating in his broker statement: “I was not associated with the activity contained in the allegations in the original statement of claim, as I was not the representative that handled the claimants account.”
The case settled on April 3, 2024, with no payment from Girgis ($0 settlement amount, $0 individual contribution). This outcome supports his claim that he was not the responsible party in this particular matter.
The Connection Between Outside Business Activities and Customer Complaints
The timing and nature of Girgis’s disclosures suggest potential connections between his outside business activities and the customer trading complaints:
FINRA’s Investigation Timeline – The investigation that led to Girgis’s bar began in 2019 (case number 2019060753512), examining his activities at both Worden Capital Management and SW Financial.
Customer Complaint Timeline – The first customer complaint was filed in early 2022, involving his time at Worden Capital. The second was filed in late 2022, involving his time at SW Financial.
Investigation Focus – FINRA specifically investigated both his outside business activities and his trading activity in customer accounts—suggesting the regulator may have been examining whether undisclosed outside business activities influenced or related to the trading practices customers complained about.
Brokers sometimes use outside business entities to circumvent firm supervision, generate undisclosed compensation, or engage in investment-related activities that their registered firm doesn’t approve. When outside business activities involve investments or create conflicts of interest, they can lead to both regulatory violations and customer harm.
Girgis’s Career Trajectory and Multiple Firm Changes
John Girgis’s 20-year career in the securities industry involved frequent moves between smaller broker-dealers, a pattern that sometimes raises supervisory concerns:
Registered Firms:
- Garden State Securities, Inc. (May 2024 – October 2025) – Red Bank, NJ
- SW Financial (December 2019 – March 2023) – New York, NY
- Worden Capital Management LLC (November 2016 – December 2019) – New York, NY
- Legend Securities, Inc. (August 2013 – November 2016) – New York, NY
- Joseph Gunnar & Co. LLC (June 2012 – August 2013) – Staten Island, NY
- Brookstone Securities, Inc. (October 2009 – June 2012) – Staten Island, NY
- J.P. Turner & Company, L.L.C. (August 2006 – November 2009) – Staten Island, NY
- GunnAllen Financial, Inc. (August 2005 – August 2006) – Staten Island, NY
This pattern of moving between firms every 2-3 years is noteworthy. While job changes are common in the securities industry, frequent moves—particularly between smaller firms—can sometimes indicate:
- Difficulty maintaining compliance standards at previous firms
- Seeking less stringent supervision
- Following a particular business model that larger firms won’t accommodate
- Regulatory or performance issues at prior firms
Several of the firms Girgis worked for have themselves faced regulatory scrutiny or have since closed, which is common among smaller broker-dealers operating in the penny stock and OTC markets.
Outside Business Activities: The Amazon Connection
Girgis’s FINRA records show he disclosed working at Amazon.com in Avenel, New Jersey, in a shipping/receiving position for approximately 10 hours per week, noting this work was “not during trading hours” and was “not investment-related.”
He also disclosed ownership of TACG Management Inc., located at 59 Summit Place, Staten Island, NY, which he described as non-investment-related and used for “paying expenses for tax purposes,” spending approximately 2 hours per month on this activity starting in April 2023.
While these disclosed activities appear benign, the question remains: were there other outside business activities that Girgis failed to properly disclose, and were those activities what FINRA was investigating when it requested his testimony?
The fact that FINRA’s investigation specifically focused on “outside business activities” suggests regulators had concerns about business dealings beyond what was properly reported. When brokers refuse to testify about such matters, it typically indicates they have information they prefer not to provide under oath.
The Significance of Permanent Industry Bars
A permanent FINRA bar is one of the most severe sanctions available to securities regulators. It means:
No Return to the Industry – Unlike suspensions, which are temporary, bars are indefinite and effectively end a career in registered securities.
Reputational Impact – Bars remain on a broker’s permanent record and are publicly available through BrokerCheck, making it virtually impossible to work in financial services.
No Associated Person Status – Barred individuals cannot work for FINRA member firms in any capacity—not as brokers, supervisors, compliance officers, or even in clerical roles involving securities activities.
Limited Appeal Rights – Bars resulting from refusing FINRA Rule 8210 testimony are particularly difficult to challenge, as cooperation with investigations is considered a fundamental condition of industry participation.
While some brokers eventually seek reinstatement after bars (through a complex and rarely successful process), bars for refusing to testify about investigations are among the most difficult to overcome.
Warning Signs of Problematic Outside Business Activities
Girgis’s case highlights several red flags investors should watch for regarding brokers’ outside business activities:
Undisclosed Business Relationships – Brokers are required to disclose all outside business activities to their firms. Undisclosed activities can create hidden conflicts of interest.
Investment-Related Outside Activities – When brokers engage in investment-related activities outside their registered firms, they may be circumventing supervision and compliance oversight.
Entities Used for “Tax Purposes” – While legitimate tax planning is normal, entities described primarily for tax purposes sometimes mask other business activities.
Excessive Job Turnover – Frequent moves between firms, especially smaller broker-dealers, can indicate compliance issues or business practices that larger firms won’t accommodate.
Refusal to Provide Information – When brokers refuse to answer regulators’ questions, it suggests they have information they don’t want to disclose.
The Impact of Penny Stock and OTC Trading Allegations
Both customer complaints against Girgis involved over-the-counter (OTC) equities and listed stocks. OTC securities, particularly penny stocks, carry significant risks and are frequently involved in customer complaints due to:
High Volatility – Penny stocks can experience dramatic price swings, leading to substantial losses.
Liquidity Issues – OTC stocks often have limited trading volume, making it difficult to exit positions without significant price impact.
Limited Information – Many OTC companies have minimal public disclosure requirements, making proper due diligence difficult.
Higher Commission Structures – Brokers often receive higher compensation for selling OTC securities, creating incentive for unsuitable recommendations.
Churning Concerns – The combination of high volatility and high commissions can make penny stocks particularly susceptible to churning schemes.
Regulatory Scrutiny – FINRA pays particular attention to brokers who concentrate business in penny stocks and OTC securities due to the higher risk of abuse.
Can You Recover Losses from Churning or Unauthorized Trading?
If you suffered losses due to excessive trading, unauthorized transactions, or unsuitable investment recommendations, you may be entitled to recover your losses through FINRA arbitration.
Churning occurs when brokers execute excessive trades in customer accounts primarily to generate commissions rather than to serve the customer’s investment objectives. Key elements of churning claims include:
- Control over the account (either actual discretionary authority or de facto control)
- Excessive trading activity given the account’s investment objectives
- Broker acted with intent to defraud or reckless disregard for the customer’s interests
Unauthorized trading involves executing transactions without the customer’s knowledge or permission, representing a clear violation of securities laws and customer rights.
Patil Law, P.C. represents investors nationwide who have been harmed by broker misconduct, excessive trading, and unauthorized transactions. Our firm has over 15 years of experience in securities law and has 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.
We handle cases involving:
- Churning and excessive trading
- Unauthorized transactions
- Unsuitable recommendations
- Breach of fiduciary duty
- Penny stock and OTC securities fraud
- Failure to supervise
We work on a contingency fee basis, meaning you pay no attorney fees unless we recover money for you. Your consultation is completely free and confidential.
Understanding FINRA Rule 8210 and Broker Obligations
FINRA Rule 8210 grants the regulator broad authority to conduct investigations and examinations. The rule requires registered persons and member firms to:
- Provide documents and information requested by FINRA staff
- Appear for testimony when requested
- Testify truthfully and completely
- Respond to requests within specified timeframes
Failure to comply with Rule 8210 requests is considered a severe violation because it undermines FINRA’s ability to regulate the industry and protect investors. The rule is so fundamental that refusing to comply almost always results in a permanent bar from the industry.
When FINRA issues Rule 8210 requests, it typically means regulators have identified potential issues requiring investigation. These investigations might be triggered by:
- Customer complaints
- Trading pattern analysis
- Regulatory examinations
- Tips from other sources
- Routine compliance reviews
Registered persons who comply with investigations and provide testimony may face disciplinary action if wrongdoing is discovered, but those who refuse to cooperate face automatic bars regardless of whether underlying misconduct existed.
Frequently Asked Questions
Why was John Girgis barred from the securities industry?
John Girgis was permanently barred from the securities industry effective September 30, 2025, after he refused to appear for on-the-record testimony requested by FINRA. The testimony was part of an investigation into his outside business activities and trading activity in customer accounts while he was associated with Worden Capital Management LLC and SW Financial. Rather than provide the requested testimony, Girgis signed an Acceptance, Waiver and Consent agreement accepting the permanent bar.
What happens when a broker refuses to testify to FINRA?
When a broker refuses to comply with FINRA’s request for testimony under Rule 8210, it typically results in an automatic permanent bar from the securities industry. This sanction is imposed because cooperation with regulatory investigations is considered a fundamental condition of being registered to sell securities or provide investment advice. The bar prevents the individual from associating with any FINRA member firm in any capacity and effectively ends their career in the registered securities industry.
What are outside business activities and why do they matter?
Outside business activities are any business activities a broker engages in beyond their registered securities work. These might include owning other businesses, serving as an officer or director of companies, or providing services unrelated to securities. Brokers must disclose all outside business activities to their firms because such activities can create conflicts of interest, divide the broker’s attention, or involve investment-related services that circumvent firm supervision. Undisclosed outside business activities can lead to regulatory violations and potential harm to customers.
What is churning and how can investors identify it?
Churning is excessive trading in a customer’s account conducted primarily to generate commissions for the broker rather than to benefit the customer. Warning signs include frequent buying and selling of securities with little apparent strategy, high commission charges relative to account size, trading that doesn’t match your stated investment objectives, and account turnover rates that seem unreasonably high. Churning violates securities laws and industry rules, and victims may be entitled to recover losses through arbitration.
Can I recover losses if my former broker has been barred from the industry?
Yes, you can still pursue recovery even if your broker has been barred. FINRA arbitration claims are typically filed against both the individual broker and the brokerage firm where they worked. Brokerage firms can be held liable for their employees’ misconduct through failure to supervise or under respondeat superior principles. Even if the individual broker has no assets or is no longer in the industry, the firm may still be responsible for compensating customers for losses resulting from the broker’s misconduct.
How do I check if my broker has any regulatory problems?
You can check any broker’s disciplinary history, customer complaints, and employment history for free using FINRA’s BrokerCheck system at brokercheck.finra.org. Simply search for the broker by name or CRD number to view their complete record, including any regulatory actions, customer disputes, employment terminations, and other disclosure events. Investors should review their broker’s BrokerCheck record before opening an account and periodically thereafter to monitor for any new disclosures.
Contact Patil Law for a Free Case Evaluation
If you have questions about churning, unauthorized trading, or broker misconduct, contact Patil Law, P.C. for a free, confidential consultation. Our experienced securities attorneys can review your case and explain your legal options.
Call us today at 800-950-6553 or email info@patillaw.com
We represent investors nationwide and work on a contingency fee basis—you pay nothing unless we recover money for you.
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, unsuitable recommendations, 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, and failure to supervise.
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.
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.