Name: William J. Money
This Broker Currently
Works For: Average
Mr. Money was born in 1949.
He maintains a post office box in Little Rock,
Arkansas, but has lived in Litchfield Park, Arizona
(a suburb west of Phoenix) since February 2006.
He holds an Airline Transport Pilot’s license.
Property records show that he owns at least two
boats, one manufactured by Polaris and the other
He is involved in at least two outside businesses,
one of which appears to be a company that owns
real estate in and around Little Rock, Arkansas.
He also owns a fireworks company, Sunflower Fireworks,
Inc. NASD records also disclose that he sells
non-variable insurance products through a separate
In 1981, Mr. Money became licensed
to sell securities, although NASD records do
not indicate where he worked at the time. In
1985, he became a registered representative
of Average Brokerage (“Average”). In March 1989
and again in August 1989 he failed the test
that would have authorized him to supervise
other brokers. He finally passed that exam in
We found one customer complaint
against Mr. Money. In 2003 a customer filed
an arbitration action accusing Mr. Money of
unauthorized trading, churning, and unsuitability.
NASD records reflect a settlement of that arbitration
with a payment of $200,000 to the customer.
In addition, the publicly available records
contain a significant gap in Mr. Money’s employment
history. NASD records do not reflect who he
worked for between 1981, when he first became
licensed to sell securities, and 1985, when
he went to work for Average.
A clean disciplinary record
is important. Mr. Money has one arbitration
action on his record. In IW’s experience, Average
rarely settles claims unless there is a good
chance that the arbitration panel will find
against the broker.
IW is also concerned with the
sale of variable annuity products to this client.
Such products are expensive to the customer,
lucrative to the broker, rarely outperform alternative
investments, even after taxes are considered,
and are almost never suitable for senior citizens
seeking income and safety of principal.
Another area of concern is Mr.
Money’s operation of outside businesses. Through
many years of protecting investors, IW has learned
that problem brokers often have outside business
Mr. Money’s firm, Average, is
an independent broker-dealer headquartered in
Boston. Average has been sanctioned numerous
times by securities regulators.
In May 1997, the Kansas
Securities Commissioner sanctioned
Average for failure to adequately supervise
one of its registered representatives who had
mistreated no fewer than four Average customers.
In June 1999, the New
Hampshire Bureau of Securities Regulation
sanctioned Average and ordered it to refund
excess commissions it had collected.
In March 2000, the North
Dakota Securities Commissioner
sanctioned Average for failure to adequately
supervise and failure to prevent sales practice
In February 2003, the NASD
sanctioned Average, finding that the firm’s
supervisory system did not provide for supervision
reasonably designed to achieve compliance with
applicable securities laws and regulations.
In February 2004, the NASD
censured and fined Average more than $2.2 million
for failing to give its customers commission
discounts to which they were entitled and for
failure to adequately supervise its representatives.
In February 2004, the U.S.
Securities and Exchange Commission
issued a cease-and-desist order against Average
for failure to give customers commission discounts
to which they were entitled. The SEC also fined
Average $1.1 million.
In November 2004, the NASD
censured and fined Average $450,000 for failing
to timely file 390 amendments to Forms U4 and
U5 which, if timely filed, would have put the
public on notice of 390 additional regulatory
actions or criminal actions by Average representatives.
In November 2005, the NASD
sanctioned Average for failing to maintain a
system of written procedures to supervise its
In December 2005, the NASD
censured and fined Average $2.4 million for
inadequate supervisory and compliance policies
In June 2005, the NASD
censured and fined Average $3.6 million for
violations involving allowing mutual fund companies
to have undue influence on Average’s sales force.
This pattern concerns IW. Adequate
supervision is essential to investor protection.
In light of the forgoing, IW gives Mr. Money
an IW score of 47
on a scale of 40 to 80. A score of 40 indicates
a broker that, in IW’s opinion, the client should
avoid altogether. A score of 80 indicates a
broker who has been tested by bear markets and
yet has no customer complaints, no disciplinary
history, no negative information in the IW database,
and no areas that raise concern for a former
SEC Enforcement Branch Chief.
IW rates brokers on a 40 to 80 scale with a
higher score reflecting IW’s opinion, based
on historical information, that the investor’s
assets are safe from intentional or reckless
misconduct by the broker or his firm. IW expresses
no opinion on the value of the customer’s investments
or on the broker’s investment selection ability.
A single new fact can radically change the IW
score and indicate a need for immediate action.
Please consider upgrading to enhanced or maximum
protection through IW’s Wiinnow™ or Constant