An AWC was issued in which Guttman was barred from association with any FINRA member in all capacities. Without admitting or denying the findings, Guttman consented to the sanction and to the entry of findings that he sold more than $7,000,000 worth of membership interests in at least six different limited liability companies to 31 customers of his member firm, and seven non-customers, without first disclosing the sales to the firm. The findings stated that Guttman participated in the sales of these membership interests by soliciting the membership interests to investors; communicating with investors about their investments; drafting, distributing and collecting the investment agreements from each investor; collecting and depositing investors’ checks into the companies’ bank accounts; and managing the companies as one of only two managing members. (FINRA Case #2017055800301)
